HC 163 Published on 10 July 2009

by authority of the House of Commons London: The Stationery Office Limited

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House of Commons

Transport Committee

The use of air space

Fifth Report of Session 2008–09

Report, together with formal minutes, oral and written evidence

Ordered by the House of Commons to be printed date 1 July 2009

The Transport Committee

The Transport Committee is appointed by the House of Commons to examine the expenditure, administration and policy of the Department for Transport and its associated public bodies.

Current membership

Mrs Louise Ellman MP (Labour/Co-operative, Liverpool Riverside) (Chairman) Mr David Clelland MP (Labour, Tyne Bridge) Mr Philip Hollobone MP (Conservative, Kettering) Mr John Leech MP (Liberal Democrat, Manchester, Withington) Mr Eric Martlew MP (Labour, Carlisle) Mark Pritchard MP (Conservative, The Wrekin) Ms Angela C Smith MP (Labour, Sheffield, Hillsborough) Sir Peter Soulsby MP (Labour, Leicester South) Graham Stringer MP (Labour, Manchester Blackley) Mr David Wilshire MP (Conservative, Spelthorne) Sammy Wilson MP (Democratic Unionist, East Antrim) The following were also members of the Committee during the period covered by this report: Clive Efford MP (Labour, Eltham) David Simpson MP (Democratic Unionist, Upper Bann)

Powers

The Committee is one of the departmental select committees, the powers of which are set out in House of Commons Standing Orders, principally in SO No 152. These are available on the Internet via www.parliament.uk.

Publications

The Reports and evidence of the Committee are published by The Stationery Office by Order of the House. All publications of the Committee (including press notices) are on the Internet at www.parliament.uk/transcom.

Committee staff

The current staff of the Committee are Annette Toft (Clerk), Jyoti Chandola (Second Clerk), David Davies (Committee Specialist), Marek Kubala (Inquiry Manager), Alison Mara (Senior Committee Assistant), Jacqueline Cooksey (Committee Assistant), Stewart McIlvenna (Committee Support Assistant) and Hannah Pearce (Media Officer).

Contacts

All correspondence should be addressed to the Clerk of the Transport Committee, House of Commons, 7 Millbank, London SW1P 3JA. The telephone number for general enquiries is 020 7219 6263; the Committee’s email address is transcom@parliament.uk

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Contents

Report Page

1 Introduction 3

2 The management of airspace 4 Current roles and responsibilities 4 Civil and military arrangements for use of airspace 6 Safety 7

3 Strategy, change and co-ordination in airspace management 8 Airspace Change Process 8

Presentation of options for airspace change 8 Establishing controlled airspace around airports 9

Airspace Master Plan 9 Joining up airport development and airspace planning 11 The third runway: airspace implications 12 New technologies and techniques 13

Precision Area Navigation (P–RNAV) 14 Continuous Descent Approaches 15

Communication by the CAA’s Directorate of Airspace Policy 16

4 Environmental impacts of airspace changes 17 Over-flying tranquil areas 17 Department for Transport’s environmental guidance to the CAA 18

5 European developments 20 Network management function 21 Extension of EASA’s safety responsibilities 22 SESAR 23

6 Conclusion 23

Conclusions and recommendations 25 The management of airspace 25 Strategy, change and co-ordination in airspace management 25 Environmental impacts of airspace changes 26 European developments 27

Formal Minutes 28

Witnesses 29

List of written evidence 30

List of Reports from the Committee during the current Parliament 32

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1 Introduction 1. The Government’s Future of Air Transport strategy aims to significantly increase UK airport capacity over the next two decades to accommodate the predicted growth in demand for air travel. New runways at Heathrow and Stansted airports are two of the key airport development proposals, first set out in the 2003 Future of Air Transport White Paper. If all the White Paper-supported airport development proposals came to fruition, current Government forecasts predict that the number of passengers passing through UK airports will increase from 241 million passengers a year in 2007 to 455 million passengers a year in 2030. This UK growth matches air traffic predictions for the whole continent. Eurocontrol, the European Organisation for the Safety of Air Navigation, predicts that European air traffic will double by 2020.

2. If rising demand for air travel is to be met effectively through additional airport capacity, a corresponding increase in airspace capacity must be realised. However, a country’s airspace—the portion of atmosphere above its territory and territorial waters, controlled by that country—is a finite resource. UK airspace, particularly in the South–East of England, is already some of the busiest and most complex to manage in the world. NATS (formerly National Air Traffic Services) handled nearly 2.5 million flights in 2007, with 1.4 million (up to 4,500 flights per day) handled over southern England. The interactions of flight routes serving a large number of airports within a relatively small geographical area in the South–East are a major limiting factor to increasing airspace capacity. Nearly doubling the number of air passengers flying by 2030 will almost certainly require improvements in the efficiency of the UK air traffic management system.

3. Accommodating the forecast growth in air traffic presents significant challenges for those organisations primarily responsible for managing UK airspace—the Civil Aviation Authority (CAA), the planner and regulator of UK airspace, and NATS, the monopoly provider of air traffic control services to aircraft flying in UK airspace. The primary challenge is how to maintain the UK’s current high standards in air traffic management whilst the airspace over the UK and the rest of Europe becomes even busier over the coming decades. This will require greater co-ordination and shared practices. And, given the Government’s climate change commitments, and the requirements being placed on the aviation industry by the EU Emissions Trading Scheme, a further challenge is how we can improve flight efficiency, and thus reduce aircraft fuel burn. These challenges must be met without diminishing the commitment to high standards of safety.

4. Our inquiry aimed to shed light on how to meet these challenges. Our findings are aimed at those organisations responsible for airspace-related decisions in the UK: the CAA, NATS, and the Department for Transport. We examined what changes were required to airspace and air traffic management to accommodate the additional airport capacity outlined in the 2003 White Paper, and the progress to date in preparing for such necessary changes. We considered the safety implications of increased airspace utilisation, the current arrangements between civil, military and general aviation users, the opportunities to apply new technologies and techniques to improve efficiency and environmental performance, and the important developments occurring at European Union (EU) level to harmonise air traffic management across Europe.

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5. We recognise that the near-term future of the aviation industry remains uncertain. Passenger numbers and freight demand globally have declined in 2008 and in the first months of 2009. The International Air Transport Association has predicted that EU airlines will face a collective loss of $9 billion in 2009. Further uncertainty is added by the Competition Commission’s ruling that BAA Airports Ltd must sell three of its major UK airports. We examine these issues in our current inquiry on the Future of aviation which will report later in the year. In that inquiry, we will also address more general airport-related topics, such as the suggested Thames Estuary airport.

6. We are grateful to all those who provided written and oral evidence to our inquiry. We also wish to thank our specialist adviser Peter Brooker for his contribution.1

2 The management of airspace

Current roles and responsibilities

7. Several organisations have responsibility for UK airspace management and design. The Department for Transport is responsible for overall aviation policy, but has a minimal role in airspace policy. Its main airspace role relates to the setting of guidance and directions for the Civil Aviation Authority (CAA), the UK’s aviation regulator. The CAA, specifically its Directorate of Airspace Policy (DAP), is responsible for the planning and regulation of all UK airspace. Its overarching duty is to maintain a high standard of safety in the provision of air traffic services. This takes precedence over its other objectives, such as securing the most efficient use of airspace, satisfying the requirements of users of all aircraft (commercial aviation, military, and general aviation), and taking account of environmental objectives in line with Government guidance.

8. At the operational level, NATS (formerly National Air Traffic Services) is the monopoly provider of air traffic control services to aircraft flying in UK airspace, and over the north–east quadrant of the North Atlantic. A public-private partnership since 2001, NATS also provides air traffic control services on a commercial basis at 15 of the UK’s largest airports, including Heathrow and Gatwick. The Ministry of Defence provides air traffic control services for operational military aircraft.

9. European bodies also play an important role in the management of UK airspace. Although EU Member States hold sole responsibility for the design and management of their airspace, these activities are co-ordinated for 25 of the states under a co-operative agreement within Eurocontrol, the European Organisation for the Safety of Air Navigation. Moreover, since 2004, air traffic management has been brought under the EU common transport policy, which aims to lay down common rules applicable to international transport originating in, destined for, or passing through the territory of EU Member States.2 The European Commission is leading on the Single European Sky

1 Declared interests as of June 2009: (1) Employed by Helios Technology, consultancy. Holder of loan stock in the

company.

2 Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions, SEC(2008)2082.

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initiative, which aims to create a harmonised European air traffic management system by 2020.

10. The majority of our witnesses were complimentary about the competence and professionalism of both the CAA and NATS. The International Air Traffic Association (IATA) described the CAA as a “centre of expertise” that discharged its statutory responsibilities for safety “very efficiently”, and airlines commended the CAA’s professionalism.3 NATS was described by a US aerospace company as a “very progressive” air navigation service provider, focussed on improving both the operational utilisation of the air traffic management system and its own internal efficiency as an organisation.4 The Society of British Aerospace Companies said that NATS was doing “terrific work” to maintain high levels of safety within “saturated” UK airspace.5

11. Some suggested the relationship between the various organisations was too close. One environmental organisation told us there was a perception outside the aviation industry that a “revolving door” existed between the Department for Transport, the CAA, and NATS, and that the relationships between them were “damaging to public confidence in policy making”. It wanted responsibility for airspace decision-making to be placed in the hands of a body “completely independent of NATS and the aviation industry”, and suggested the Environment Agency’s role be extended to cover this.6

12. Other industry representatives, however, rejected this suggestion. IATA believed it was right that the CAA had responsibility for airspace decision-making: it noted that airspace policy was an extremely “specialised area” and the CAA had “built up a lot of expertise in managing and changing airspace”. Furthermore, establishing some kind of parallel decision-making process with the Environment Agency risked “complicating decision making”.7 A British Airways representative commented that environmental concerns were now high on the agenda right across the industry, so there was no rationale for the Environment Agency to be given such a responsibility.8 The Minister strongly denied the view that the relationship between the existing organisations was too close, and he was content to have these relationships publicly scrutinised in order to prove so. 9

13. Eurocontrol told us that the UK model for airspace management—with the CAA as regulator and NATS as service provider—had, in fact, been “an example for many [other European] states to follow”, and was therefore “very positive”.10 We agree with the majority of witnesses that the current general organisational structure of airspace management is entirely appropriate. It was clear from our evidence that most of the aviation industry did not support, or want, radical change in the current responsibilities for airspace management and decision-making.

3 Qq 213–214, 249.

4 Q 177

5 Q 198

6 Ev 182

7 Q 249

8 Q 249

9 Q 523

10 Q 285

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Civil and military arrangements for use of airspace

14. Airspace is shared by several different users who sometimes have diverging interests. One of the CAA’s objectives as airspace planner and regulator is to satisfy the requirements of users of all aircraft. As part of our inquiry, we examined whether the current balance between the civil and military users of airspace was fair and equitable. The ability to strike a fair and equitable balance will no doubt become increasingly difficult as demands on UK airspace increase over the coming decades.

15. We are pleased that most witnesses believed that the interface arrangements between military and civil use of airspace worked well. The Ministry of Defence was satisfied with the current arrangements and regarded its relationship with other stakeholders in the aviation community in a “very positive light”. It noted, however, that increased air travel over the period of the White Paper would inevitably “place stresses on airspace and on airspace structures”.11 NATS agreed that the interface arrangements were “extremely good”; in fact, they were “significantly better than elsewhere in Europe”. It stressed that the anticipated growth in air travel outlined in the Government’s White Paper would require “greater flexibility to accommodate civil flights during peak periods”.12

16. Airline and airport operator representatives told us that the arrangements were effective at the operational level but less so at the strategic level. The military was said to have precedence over commercial interests in some circumstances, simply as a result of historical or legacy factors.13 Birmingham International Airport noted that the size of the Royal Air Force had reduced significantly in recent decades without corresponding changes in airspace allocation. It questioned whether the allocation of military airspace remained appropriate.14 When questioned on this issue, the CAA acknowledged that fewer military aircraft were now in operation than in previous years. However, new, advanced military aircraft, such as the Eurofighter, required larger amounts of airspace to operate in compared to earlier models of military aircraft.15

17. The CAA told us it essentially had to perform a “balancing act” to satisfy the interests of the different users of airspace.16 To help achieve this balance, the authority’s Directorate of Airspace Policy (DAP) was staffed by experts from a wide range of operational aviation backgrounds, including commercial, business, recreational, and military aviation. We note, however, that the great majority of DAP Directors and Deputy Directors are current or ex-officers at the Ministry of Defence. We believe it should be an unambiguous objective of CAA staff planning that senior postholders within the Directorate of Airspace Policy represent the broad spectrum of operational expertise in a well-balanced manner.

11 Q 252

12 Ev 176

13 Ev 123; Ev 103

14 Q 404

15 Q 526

16 Q 53

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Safety

18. The UK has an excellent aviation safety record. It is clear from our inquiry that this record has been achieved by a team effort across the whole industry. A key airspace safety indicator is the annual number of Airproxes17 involving commercial air transport, which has shown welcome reductions over the last decade.18

19. Some witnesses were concerned that the busier skies forecast for the coming decades could have repercussions for safety. Chiltern Countryside Group said safety would be compromised if more aircraft movements were allowed in the “already over-crowded” airspace in the South–East.19 The Air Safety Group and the Parliamentary Advisory Council for Transport Safety (PACTS) were concerned about the increasing complexity of air traffic control, particularly that increased reliance on computer tools might pose problems in the event of a major system failure.20

20. We welcomed the assurances from NATS, the CAA and industry witnesses that safety was paramount and would not be compromised as airspace was increasingly utilised.21 The CAA said safety was its primary air navigation duty. It would “take any actions necessary” to ensure that safety was not compromised and that the high safety standards within UK airspace, and its supporting infrastructure, were maintained, with “potential risks identified and appropriate mitigating actions taken”.22 NATS believed that “improved procedures and new technology and air traffic control tools” would help to ensure airspace capacity increased safely over the coming decades.23 An aerospace company told us that safety was a paramount consideration for the aviation industry, because safety problems were inevitably bad for business.24

21. As part of the EU Single European Sky proposals, the European Aviation Safety Agency will have its remit extended to include the safety of air navigation services and air traffic management. We discuss this development in chapter 5 below.

22. Our evidence has demonstrated there is much to commend in the current management of UK airspace. We have been particularly impressed by the technical competence and professionalism of the CAA and NATS. We reject suggestions that responsibility for decision-making about airspace be placed in a different organisation. We see no apparent and significant benefits from such a transfer.

17 An Airprox is defined as a situation in which, in the opinion of a pilot or controller, the distance between aircraft as

well as their relative positions and speed was such that the safety of the aircraft involved was, or may have been, compromised.

18 Civil Aviation Authority, CAP 780: Aviation Safety Review 2008, November 2008, Chapter 16, p 15

19 Ev 115

20 Ev 130

21 Qq 179–180; Ev 198; Ev 176

22 Ev 198

23 Ev 176; Q 348

24 Q 179

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3 Strategy, change and co-ordination in airspace management 23. Many witnesses were, on the whole, content with the current management of UK airspace. The main concerns we heard were rooted in a fear about the potential future impact of the Government’s White Paper plans (to almost double the number of air travel passengers by 2030) on our already busy skies, particularly in the South–East of England. We examined several aspects of airspace management likely to become increasingly pertinent within this context of long-term, major growth in air travel. These included airspace design and planning processes, co-ordination and communication, and new air traffic management technologies and techniques.

Airspace Change Process

24. Data on flight efficiency suggest that flights within Europe consume between 7–11% excess fuel, partly caused by indirect and non-optimal flight routeings.25 Changes to airspace design—for example, the redistribution of certain flight paths—are sometimes necessary to improve flight efficiency, to reduce delays, or to allow an increase in flights due to airport expansion. Such changes are usually proposed by air navigation service providers (most often NATS) or by airports themselves. It is estimated that changes made in January 2008 to the airspace structure linking the Midlands to the south of England will reduce flight delays, thus saving £68 million over eight years, and reduce annual CO₂ emissions by about 3% on those routes.26

Presentation of options for airspace change

25. A formal “Airspace Change Process”, including a consultation process, must be undertaken each time a proposal is made to change airspace. The CAA sets guidance on the process, specifying which information must be included in the proposal and who should be consulted. The CAA also makes the final decision on the airspace change proposal; it therefore holds ultimate responsibility for airspace changes.

26. The CAA’s Airspace Change Process guidance document—CAP 725—states that airspace change sponsors “should consider and assess more than one option” in their proposal.27 Some environmental bodies and local interest groups strongly criticised the recent Terminal Control North (TCN)28 airspace change consultation because the sponsor,

25 Eurocontrol Performance Review Commission, Vertical Flight Efficiency, March 2008

26 Although the exact amount of the CO₂ reduction is difficult to deduce using existing models and should therefore be treated with some caution. CAA Decision Letter, Changes to the existing airspace structure that links the Midlands to the South Coast, 29 January 2008.

27 Civil Aviation Authority, CAP 725: CAA Guidance on the Application of the Change Process, March 2007, Appendix B, p 7

28 The Terminal Control North area region is one of the most complex areas of airspace in the world, with routes in and out of a number of major airports including Heathrow, Stansted, Luton, and London City. The proposal is being designed to reflect the growth in air services over the past 15 years, as well as accommodating the forecast air traffic arising from general airport growth under the provisions of the Government’s 2003 White Paper.

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NATS, only offered one option for airspace change.29 The TCN region in the south of England covers a population of 12 million people, and the proposal was billed by NATS as “the biggest ever consultation on airspace change”.30 The lack of any alternative option presented by NATS was raised in the House.31 Following much criticism, NATS announced a second Terminal Control North consultation on revised proposals to redraw the aircraft route map in the TCN region in February 2009.

27. It is fundamental that those affected by airspace changes are presented with more than one option, assuming this is possible, during the consultation process. The CAA must encourage airspace change sponsors to follow the guidance requirement for more than one option to be presented, if possible.

Establishing controlled airspace around airports

28. Controlled airspace is essentially airspace in which aircraft receive an air traffic control service. Air traffic controllers endeavour to ensure that flights are on non-conflicting routes and they provide instructions to pilots when they see the possibility of a conflict. Above 19,500 ft (the area where international flying takes place) all airspace is controlled. Below 19,500 ft, approximately 40% of airspace is controlled.32 Military and general aviation largely operate outside controlled airspace, in uncontrolled, or ‘Class G’, airspace. Uncontrolled airspace means that an air traffic control service is not provided: it is predominantly a “see and avoid” environment.

29. General aviation representatives told us that NATS and the CAA often established excessive amounts of controlled airspace around airports. Glasgow Airport was said to have three times the controlled airspace of Gatwick Airport, despite handling only a third of the number of flights. Doncaster Airport had recently been awarded controlled airspace slightly larger than Gatwick but only had 2% of the number of flights handled at Gatwick.33 The Light Aircraft Association asserted that the CAA was out of line with continental European airspace designers in this respect; the equivalent German controlled airspace was said to be 40% narrower.34

30. The CAA and NATS should review the techniques used for designing controlled airspace around airports. The techniques used should match European and USA best practice standards to minimise the impact on general aviation, whilst ensuring safety and that current standards are not lowered.

Airspace Master Plan

31. The Government’s 2003 White Paper recognised that the additional airport capacity proposed “must be matched by a corresponding increase in airspace capacity”. The

29 Q 136 [2M Group]; Q 162 [Campaign to Protect Rural England]

30 “Biggest ever airspace consultation launched”, NATS press release, 21 March 2008.

31 21 May 2008, col 122WH

32 Q 526 [CAA]

33 Ev 247

34 Q 495

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Government therefore called for the CAA to “bring forward a structured programme for the redesign of UK airspace that would help to protect safety standards, relieve current constraints, take account of environmental impacts and accommodate the forecast increase in air transport movements where additional capacity was supported in the White Paper”.35

32. The majority of organisations submitting evidence to our inquiry believed some kind of “Airspace Master Plan” for the period of the White Paper (up to 2030) was necessary. Airlines, airport operators, and air traffic control representatives criticised the current “piecemeal” approach to airspace planning.36 Some witnesses were concerned, however, that a master plan could pre-empt the consultation process that currently occurs under the Airspace Change Process, each time there is a proposal to re-design airspace.37 Others agreed that it was unrealistic to plan for every possibility, due to the unpredictable nature of airport development planning.38

33. The CAA recently commissioned NATS, as the monopoly en-route service provider, to initiate a study into the future requirements for airspace, air traffic management and navigation policy for the busiest portions of UK airspace. This study, the Future Airspace Strategy (FAS), has the objective of setting out “a strategic plan for the reorganisation of the busiest portions of UK airspace out to 2025 so as to ensure safety, secure airspace efficiency and deliver the greatest degree of environmental mitigation, whilst ensuring cohesiveness with European strategies”.39 We were told that a project definition stage for the FAS had recently been launched.40

34. It is apparent from our evidence that many witnesses support the general principle of a long-term Airspace Master Plan, although its nature is not well understood. We believe that an Airspace Master Plan must be well-specified if it is to add real value and be a worthwhile endeavour. The objective of an Airspace Master Plan should be to maximise the efficiency of UK airspace, whilst meeting environmental constraints and taking account of stakeholder needs. The Master Plan should indicate those geographical areas within the UK where there would be significant difficulties designing airspace. In such instances, airspace design issues would be a much more important consideration in airport development proposals. An Airspace Master Plan should also cover the likely technological developments, including the impact of the Single European Sky. There needs to be clarity about what benefits an Airspace Master Plan would bring, in particular how such a plan would improve flight efficiencies and improve the effectiveness of the Airspace Change Process.

35. When the current project definition stage has been completed, the CAA should present its framework recommendations for a Future Airspace Strategy (FAS) to the Department for Transport and the industry. This work should explain the nature of the

35 Department for Transport, The Future of Air Transport, Cm 6046, December 2003, p 146; Department for Transport,

The Future of Air Transport Progress Report, December 2006, Cm6977, p 42.

36 For example, British Airways [Ev 192, section 3], Manchester Airports Group [Ev 103, section 2.1], Guild of Air Traffic Control Officers [Ev 133]

37 General Aviation Alliance/Light Aircraft Association [Ev 247]

38 Air Safety Group/PACTS (Q 118); Redhill Aerodrome Limited [Ev 97]

39 Ev 198

40 Q 533

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FAS, the benefits to be achieved, how the strategy relates to airport development planning processes, and the impact of the strategy on the Airspace Change Process. It should describe the safeguards required to ensure that the FAS does not pre-empt the requirement for proper consultation on airspace change proposals.

36. Many witnesses criticised the length of time taken (since 2003) to make progress on an Airspace Master Plan. British Airways said there was “scant evidence to date of progress by the CAA in meeting this explicit remit from Government”.41 Airlines and airport operators were also concerned that they had not yet been consulted on the FAS work. The Airport Operators Association was concerned that, “as the representative body for UK airports”, it had not yet been invited to field any experts to contribute to this “much needed work”.42 Virgin Atlantic and British Airways also said they had not been contacted about the FAS work.43

37. We questioned the CAA about these criticisms. The CAA said that work on the FAS had in fact been taking place behind the scenes for some years. However, progress had been affected by the number of uncertainties that needed to be resolved due to their potential impact on UK airspace. These included the Government’s decision on a third runway at Heathrow and progress with the EU Single European Sky II and SESAR (Single European Sky ATM Research) initiatives. We were told that the FAS would take another two to three years to complete, and all major stakeholders would be consulted, perhaps later in 2009.44

38. The CAA could allay many concerns about the perceived slow progress in developing a long-term airspace strategy, and the lack of consultation to date on the FAS, through better communication with stakeholders. The CAA must improve its communication with key stakeholders about the ongoing work on the FAS and the likely timescales. It must ensure that stakeholders are properly consulted about the FAS when appropriate.

Joining up airport development and airspace planning

39. Several witnesses expressed concerns about the integration of the different aspects of the planning system. We were told that airport development proposals often did not adequately consider airspace implications.45 The Aviation Environment Federation wanted airspace management to be “brought forward in the planning process, if necessary, with outline permission being gained before further [airport] planning consideration is undertaken”.46 The Guild of Air Traffic Control Officers said it would “welcome the inclusion of the consideration of the potential impact on airspace and its management when airports are developing their master plans”.47

41 Ev 192

42 Ev 210

43 Q 227

44 Q 533

45 For example, the Aviation Environment Federation [Ev 163], Campaign to Protect Rural England [Q 167].

46 Ev 163

47 Ev 133

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40. The Department for Transport aims to establish a suite of ‘National Policy Statements’ that will comprise “a statement for aviation, incorporating the [Future of Air Transport] White Paper”. Under the new system, the Infrastructure Planning Commission (IPC), established under the Planning Act 2008, will have primary responsibility for deciding on applications for the development of nationally significant infrastructure projects, such as airports. The Department says:

In submitting applications for airport development, a preliminary view will need to be taken of the various options for airspace configuration and capacity requirements. Those preliminary views will form part of the application and be subject to the necessary impact assessments. However, the detailed airspace design and subsequent consultation will depend on the nature of the airport development for which IPC consent is granted.48

NATS told us that airspace was just as important a part of the airport infrastructure as runways and ground access, and that it “must be factored in to consideration of airport expansion”. It warned, however that detailed airspace design was costly and could only be applied once a policy decision had been clarified.49

41. We believe that airspace impacts should be considered a vital part of airport development proposals. It is essential that National Policy Statements (NPSs) on the development of major airport infrastructure are based on advice from the CAA and NATS about the airspace implications of proposed developments. In the case of non-location specific NPSs, the NPS should include unambiguous guidelines to the Infrastructure Planning Commission on how to evaluate the airspace implications of any proposal. It is vital that the industry is well appraised of the methods used as well as the factors and information used by the Commission in making decisions on major airport developments.

The third runway: airspace implications

42. On 15 January 2009 the then Secretary of State for Transport, the Rt. Hon Geoff Hoon MP, announced that the Government’s three conditions for supporting a third runway at Heathrow Airport had been met.50 The Government therefore invited BAA, the owners of Heathrow, to bring forward proposals to build a third runway and a sixth terminal at Heathrow. We will examine the economic and environmental implications of the third runway at Heathrow as part of our Future of aviation inquiry. In this inquiry we focussed primarily on the airspace implications of a third runway, and particularly the opportunity it presented to reduce the amount of airborne holding, or “stacking”, around the airport.

43. Stacking—whereby aircraft are kept waiting in the air around the airport before air traffic control gives permission to land—currently occurs routinely around Heathrow Airport, largely because the airport operates at about 99% of its runway capacity.51 Stacking

48 Ev 21

49 Ev 176

50 HC Deb, 15 January 2009, col 355

51 Ev 176. Aircraft at Heathrow have an average holding period of ten minutes.

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also occurs at other UK airports, but not to the same extent as Heathrow. Excessive stacking can have both environmental and economic impacts. The Omega Academic Partnership—a partnership of nine UK universities focussing on the environmental issues facing aviation—said stacking was one of the main sources of flight inefficiency, and thus fuel burn and associated emissions.52 The Boeing Company told us that reducing excessive stacking could contribute to “less noise exposure under the flight path on approach”.53 Great Thurlow Parish Council described stacking as an “anti-social and unnecessary” practice, which resulted in a “notable decrease in quality of life for a concentrated few”.54 The CAA acknowledged that stacking was an “environmental issue”.55 We were told that the authority had recently carried out a study for the Department for Transport on resilience and the economic benefits of reducing time delays, including those caused by stacking.56

44. The additional capacity provided by a new runway at Heathrow would offer the possibility of reducing the number of aircraft stacking in the sky before landing. NATS said the third runway presented an opportunity to build additional resilience into the air traffic management system and reduce aircraft queuing; in NATS’ view, it was “vital” not to schedule to maximum capacity.57 The Director General of Civil Aviation at the Department for Transport agreed that the third runway offered “an opportunity for the airport to run more effectively and […] to reduce unnecessary stacking”. He was open to the possibility of setting targets to reduce excessive stacking around the airport, and suggested the CAA could play a role in setting and monitoring those targets.58 The CAA told us it was not part of its current remit to set and monitor such targets, but, if given the task, “it is the type of thing we could readily do”.59

45. Some “stacking” may be inevitable. But excessive stacking, such as frequently occurs at Heathrow, has negative environmental effects. A third runway at Heathrow Airport, if built, offers a real opportunity to add resilience into the air traffic management system and to help reduce excessive stacking. If a third runway is built at Heathrow, the Government should create a framework for setting targets to eliminate excessive stacking around the airport. The CAA should be given responsibility for setting and monitoring such targets. The targets should be included within the relevant National Policy Statement for the development.

New technologies and techniques

46. Air traffic management is based on core principles and technologies that have evolved only slowly in recent decades. The EU’s SESAR (Single European Sky Air Traffic Management Research) programme has ambitious aims to modernise European air traffic

52 Ev 218

53 Ev 175

54 Ev 139

55 Q 41

56 Q 520

57 Q 354; Ev 176

58 Qq 519–520

59 Q 522

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management technologies and techniques (see chapter 5), but it remains a long-term goal. We examined what opportunities existed in the nearer-term to apply new technologies and techniques within the UK, in order to reduce wasteful flying on indirect routes and excessive “stacking” while planes wait to land—both of which contribute to flights within Europe consuming some 7–11% excess fuel.60

47. Witnesses told us that the application of new technologies and air traffic management techniques would become increasingly important over the coming years, as the need for additional capacity and improved fuel-efficiency increased. BAA Airports Ltd said that the implementation of new technologies was “essential rather than desirable […] at a time when the industry is becoming seriously affected by global economic instability”.61 British Airways told us there were “many opportunities available to reduce waste and inefficiency across the air traffic control system”.62 The Boeing Company agreed that there was “scope for improving the operational performance of the UK’s airspace”, and believed that “much of the technology that can deliver improvements is in existence today”. “Continuing the status quo” would “result in greater fuel burn than theoretically necessary, with a direct increase in emissions”.63 It is clear that the development and application of new technologies and air traffic management techniques are integral to improving flight efficiency, thus reducing excessive fuel burn, and increasing airspace capacity.

48. We focus on two specific examples below: Precision Area Navigation and Continuous Descent Approaches.

Precision Area Navigation (P–RNAV)

49. Precision Area Navigation, known as P-RNAV, is a method that uses satellite navigation, ground-based aids, and on-board electronic systems to allow aircraft to self-navigate on any desired path. It differs from traditional, less flexible navigational practices whereby aircraft determine their position using ground-based beacons. P-RNAV can improve the flight efficiency of aircraft, for example by reducing the separation distances of aircraft, and can enable the use of best practice techniques, such as Continuous Descent Approaches (CDAs), with subsequent environmental benefits. P-RNAV and CDAs are valuable in their own right, but are also precursors for longer-term SESAR operational concepts.

50. Industry witnesses, academics, environmental organisations and European organisations all strongly supported greater use of P-RNAV technology. Virgin Atlantic Airways said P-RNAV could deliver “significant benefits” in terms of safety and additional capacity.64 The Guild of Air Traffic Control Officers said P-RNAV, by enabling routes to be spaced closer together, improved the efficiency of the airspace and could increase capacity.65

60 Eurocontrol Performance Review Commission, Vertical Flight Efficiency, March 2008

61 Ev 235

62 Ev 192

63 Ev 175

64 Ev 123

65 Ev 133

15

51. Modern commercial aircraft are usually fitted with P-RNAV capability, but we heard from airlines that the full benefits of the technology were not being utilised. British Airways said we had been “slow to take full advantage” of existing technology and wanted a roll-out of P-RNAV procedures to be “accelerated” with “much greater emphasis” placed on promoting the technology.66 Part of the problem was said to be that older aircraft were not equipped with the technology, which meant that airspace was still primarily designed in a traditional way. Eurocontrol told us it was “not efficient” if only some aircraft had P-RNAV capability.

52. The Department for Transport and the CAA highlighted that current airspace change proposals under development would seek to promulgate technologies such as P-RNAV.67 Despite this, the CAA does not appear to have offered clear statements to the industry and public about its broader P-RNAV strategy for the UK. In evidence to us, the CAA recognised that P-RNAV offered “tremendous benefits”, but said it was still too early to understand the full extent of those benefits. Asked about a timescale for implementing some of those benefits, the CAA was non-specific, suggesting it could perhaps be “something like a five-year period”.68

53. We have heard very wide support for Precision Area Navigation (P-RNAV), but a great deal of uncertainty remains amongst industry parties about the actual plans and commitments for the widespread introduction of this technology in the UK. The CAA should produce a strategy for P-RNAV within 12 months.

Continuous Descent Approaches

54. Aircraft have traditionally descended towards their destination in a series of steps, largely due to inherent airspace restrictions. This approach is not ideal from the perspective of either noise or fuel burn, and thus emissions. A Continuous Descent Approach (CDA) involves an aircraft descending towards an airport in a gradual, uninterrupted approach with the engine power cut back.

55. Currently, CDAs are agreed by the air traffic controllers and pilots on a flight-by-flight basis, according to weather and traffic conditions. Their use in the UK is well-established; in fact, they have been used extensively in the UK for certain airports such as Heathrow for several years. Practice varies, however, both between airports and also between airlines.69 For example, British Airways’ CDA performance at Heathrow Airport in 2007 was 95%, compared to the airport average of 83%.70 Heathrow Airport was achieving an average of 70% CDAs 30 years ago.71

66 Qq 240, 242

67 NATS has confirmed it will propose P–RNAV routeings in a second Terminal Control North (TCN) airspace change consultation.

68 Qq 548–550

69 Ev 217

70 British Airways, Corporate Responsibility Report 2007–08, p 10

71 CAA Paper 78006, The Noise Benefits Associated with Use of Continuous Descent Approach and Low Power / Low Drag Approach Procedures at Heathrow Airport.

16

56. Many witnesses, including airport operators, aerospace companies and academics, emphasised the fuel and noise reduction benefits that could be gained from employing CDA landings and advocated the adoption of this approach. The Society of British Aerospace Companies (SBAC) said CDAs resulted in average reduced fuel burn and emissions of 100 kg of fuel and 315 kg of CO₂ per flight, compared to a conventional approach, and markedly less noise exposure for communities under the early descent of the flight path. The Society noted, however, that CDA utilisation was “often limited by air traffic management resource, airspace capability or pilot uptake”.72 P-RVAV technology was also said to facilitate a higher proportion of CDA landings.

57. There is currently noticeable variation between airports and between airlines in the take-up of Continuous Descent Approaches (CDA). It is necessary to improve airports’ performance in the use of CDA landings so that the best practice standard is adhered to as near to universally as is achievable. The Civil Aviation Authority must adopt a more active role in encouraging the industry to adopt CDA. The CAA should monitor the CDA performance of major airports and airlines, publish statistics, and promote practices and changes that lead to greater utilisation of CDA.

Communication by the CAA’s Directorate of Airspace Policy

58. Our inquiry revealed several areas of “dissonance” between the perceptions of airlines, airport operators, and other stakeholders on one hand and the official line given by the CAA on the other. These include concerns from the industry about the work underway for the Future Airspace Strategy (see para. 36), uncertainties about the implementation of Precision Area Navigation (P–RNAV, see para. 51), and the general aviation community’s concerns about Mode S Transponder plans. With regards to the Future Airspace Strategy, the CAA said “the time was simply not right to engage with external stakeholders” because the proposals were at too early a stage.73 We believe better communication by the CAA with its stakeholders could have helped to address some of the concerns we heard during our inquiry.

59. We believe that many concerns from industry stakeholder could be alleviated by improved communication on the part of the CAA. The CAA should review its communication strategy in DAP (Directorate of Airspace Policy) to ensure that policy and technical matters are communicated in a timely and effective manner to all stakeholders.

72 Ev 160

73 Q 533

17

4 Environmental impacts of airspace changes 60. The environmental impact of aviation is currently a very high-profile issue. It is estimated that aviation contributed 6.3% of total UK CO₂ emissions in 2005, and the Government forecasts this proportion will grow to between 24% to 49% by 2050.74 The Climate Change Act set legally binding targets to reduce CO₂ emissions by at least 26% by 2020 and 80% by 2050. In January 2009, the then Secretary of State for Transport, the Rt Hon Geoff Hoon MP, announced that aviation emissions in 2050 should be below 2005 levels. From 2012, aviation will also be brought under the EU Emissions Trading Scheme. Emissions from airlines flying from and within the EU will initially be capped at 97% of average 2004–06 annual emissions, but this will tighten to 95% of average 2004–06 emissions from 2013.

61. We examine the broader environmental impacts of aviation in our Future of aviation inquiry. As part of this inquiry, we considered the environmental impacts of airspace changes, particularly the emissions and noise impacts of creating new flight paths or modifying existing ones, and how best to balance those impacts.

Over-flying tranquil areas

62. Several witnesses were concerned about new routeings and marked traffic growth over-flying tranquil areas. Shropshire County Council said the CAA’s West End Area Airspace Changes, implemented in March 2006, had resulted in a 21% overall increase in air traffic flying over the Shropshire Hills Area of Outstanding Natural Beauty.75 Similarly, the Campaign for National Parks strongly criticised the CAA’s Terminal Control South West decision in January 2008, which redirected flight paths over parts of the New Forest National Park.76 It was generally accepted that there was a paucity of quality research about tranquillity and the effects of aircraft on tranquil areas.77

63. The CAA said it endeavoured to avoid aircraft over-flying Areas of Outstanding Natural Beauty, in line with current guidance. However, the guidance also necessitated the CAA to make a “balanced judgement” of all the various environmental impacts, when deciding airspace changes.78

64. Tranquillity is a key factor in sensitive areas such as National Parks and Areas of Outstanding Natural Beauty. Current guidance appears to allow unchequed increases in aviation activity over these areas. Without some level of constraint, the noise environment in these areas might degrade progressively as traffic increases.

74 With no radiative forcing factor. Department for Transport, UK Air Passenger Demand and CO₂ Forecasts, January

2009, p 60, p 173.

75 Ev 107

76 Ev 94

77 For example, Shropshire County Council [Ev 107], Natural England [Ev 128], National Trust [Ev 140].

78 Qq 529–530

18

65. The DfT and the CAA should examine the case for adopting maximum limits on noise levels and numbers of aircraft permitted per hour over sensitive areas such as National Parks and Areas of Outstanding Natural Beauty. The DfT should fund exploratory research on evidence-based limits.

Department for Transport’s environmental guidance to the CAA

66. Environmental guidance set by the Department for Transport in 2002—Guidance to the CAA on the Environmental Objectives Relating to the Exercise of its Air Navigation Functions—sets a framework within which the CAA must operate when making decisions on airspace change proposals. The 19-page document states that the CAA must consider “the need to reduce, control and mitigate the environmental impacts of civil aircraft operations”, in particular aircraft noise and emissions. However, the guidance is largely discursive in nature: it does not provide a clear Governmental policy view about priorities in airspace design, other than safety being paramount. The guidance has also not been updated since 2002, despite climate change having risen up the Government’s agenda considerably in recent years. Thus, it does not take account of major shifts in Government thinking such as the Stern Review on climate change (2006) and the Eddington Transport Study (2006).79

67. Several witnesses criticised the environmental guidance as lacking clarity, especially in terms of determining the priorities of different environmental impacts such as noise and emissions. NATS argued for “greater clarity […] in […] environmental policy on matters such as concentration/dispersal of noise and the relative importance of noise and emissions; this in turn will enable clearer guidelines provided by the CAA for airspace design and future airspace rule-making”.80 The Guild of Air Traffic Control Officers said the existing guidance was “woolly”. It wanted “more prescriptive guidance” because currently there was no “clear guidance when you are designing and developing the airspace as to what environmental criteria you are meant to be adhering to”.81 The Aviation Environment Federation said:

You have got different constituents out there and the community will always be interested in noise. Increasingly, the Government will be interested in the emissions side, and the inclusion of aviation into the Emissions Trading Scheme will make sure that airlines will be saying to NATS, “Design us a system that gives us the most efficient routes in and out”, but you have got to try and reconcile that. […] I think that the CAA and NATS taking that value judgment about which to prioritise over the other is inappropriate. It is exactly why we argue that you have to have “sophisticated” guidance.82

68. We recommended, in our 2006 Report on The work of the CAA, that the Government amend its 2002 environmental guidance to give the CAA and others better information

79 The Eddington Transport Study noted that emissions from the transport sector were a significant and growing

contributor to the UK’s overall greenhouse gas emissions, and said it was essential that the environmental impacts of transport were fully reflected in decision-making.

80 Ev 176, Summary

81 Q 122

82 Q 173

19

about how to balance different environmental factors.83 The Pilling Strategic Review of the CAA, reporting in July 2008, made similar recommendations.84

69. The Department for Transport told us it was currently re-examining the 2002 guidance, following the findings of the Pilling Review.85 The Minister acknowledged that concerns about CO₂ emissions were “much more prominent” now compared to even a couple of years ago.86 The CAA said that the new guidance would have to include any relevant findings from the Stern or Eddington reports. However, it warned that the guidance was intended to be of a general nature, and there was no such thing as a “perfect formula” for the Directorate of Airspace Policy to apply. It said different environmental considerations had to be considered in different locations throughout the UK.87

70. The CAA is not an elected body and it would be inappropriate for the authority to be the final arbiter of decisions or decision-making criteria, regarding airspace design changes that have significant environmental impacts. The CAA should be basing its decisions on clear principles set out by Government on its environmental priorities, to enable the authority to better make the difficult decisions where the advantages of direct flight routeings and noise impacts have to be balanced against one another. The Department for Transport (DfT) should issue up-to-date Environmental Guidance to the CAA before the end of the year. The guidance should represent current Government thinking on CO₂ and other emissions in relation to transport decision-making. The guidance must be clear about the basic policy principles by which the Government expects the CAA to make its airspace assessments.

71. The CAA’s own airspace change guidance document, CAP 725, is partly based on the existing DfT environmental guidance.88 The process set out in CAP 725 has to be followed by those organisations proposing airspace changes, usually air traffic service providers or airports. CAP 725 is described as a “living document” subject to occasional revision.89 The environmental requirements set out in the document are out-of-date regarding key Government policy reports, such as Stern and Eddington, despite CAP 725 last being revised in March 2007. We asked the CAA whether it was satisfied that its airspace policy documents reflected current Government policy. The CAA said the documents “reflect Government policy as given to us through the [Department’s] environmental guidance”.90

72. Once the DfT has issued new environmental guidance to the CAA, the CAA must produce clear and comprehensive new guidance on airspace change for the industry. The CAA should adopt a regular review cycle to update the environmental material in the document.

83 Thirteenth Report of Session 2005–06, HC 809, para 157.

84 Sir Joseph Pilling, Report of the Strategic Review of the CAA, p 40.

85 Qq 532, 535.

86 Q 539

87 Qq 537, 540.

88 Appendix B of the document, “Airspace Change Proposal—Environmental Requirements”. See also CAA evidence [Ev 198]

89 NATS [Ev 176]

90 Q 541

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5 European developments 73. Airspace over Europe is highly fragmented, having developed largely around state geographic borders and boundaries. International flights currently have to pass through national air traffic zones or “blocks”, before being handed over from one national authority to another. For example, passenger aircraft travelling between Brussels and Rome must pass through nine different air traffic control zones. This system leads to bottlenecks and delays, forcing aircraft to consume more fuel and jeopardising safety. As a consequence, flights in Europe are on average 49 kilometres longer than needed. The European Commission estimates that the fragmentation of Europe's airspace costs €1 billion each year and that shorter, direct routes could save five million tonnes of CO₂ annually. 91

74. Important developments are taking place at the European level to create a more rational organisation of European airspace and additional capacity, whilst maintaining high safety standards. The European Commission’s Single European Sky (SES) initiative, adopted in 2004, brought air traffic management (ATM) under the EU common transport policy, which sets common rules applicable to international transport originating in, destined for, or travelling within, the territory of Member States. SES aims to create, by 2020, an ATM system designed, managed and regulated in a harmonised way. The new European ATM system is intended to sustain European aviation from an ATM viewpoint for the subsequent 30 to 40 years.92 A second package, the Single European Sky II (SES II), was published by the European Commission in June 2008, which placed greater emphasis on the potential environmental benefits to be gained through modernising the European ATM system. The package was adopted by the European Parliament in March 2009. SESAR (Single European ATM Research) is the industry-led research and technology programme accompanying the SES legislation.

75. The SES initiative received almost uniform support from witnesses submitting evidence to our inquiry. It was hoped the initiative would deliver increased capacity and environmental benefits.93 The Department for Transport confirmed to us that it “strongly supported” the SES initiative.94

76. An important SES development to date has been the creation of the UK–Ireland “Functional Airspace Block” (FAB), implemented in July 2008, which has rationalised existing airspace arrangements between the two countries. Under the 2004 SES legislation, Member States are required to establish FABs, across national boundaries, by the end of 2012. The intention is to deliver operational efficiencies across national boundaries by developing more fuel-efficient routes, improving delays and enhancing safety. The UK is also a “co-operative partner” in the development of the proposed FAB Europe Central, involving the airspace of France, Germany, the Netherlands, Belgium, Luxembourg and Switzerland—one of the highest traffic density areas in the world.

91 “EU seeks to end fragmentation of European airspace”, EUbusiness, 26 June 2008. Quote by EU Transport

Commissioner Antonio Tajani.

92 CAA [Ev 198]

93 For example, Virgin Atlantic Airways [Ev 123], Aviation Environment Federation [Ev 163], Air safety Group/PACTS [Ev 130].

94 Q 508

21

77. We support the principles of the Single European Sky (SES) initiative to create a more rational organisation of European airspace, for example by establishing cross-border Functional Airspace Blocks. It is unacceptable that, on such a crowded continent, airspace is still largely managed in isolation based on national borders. Greater harmonisation of air traffic management practices at the European level would lead to improvements in efficiency, environmental performance, and capacity. However, it is essential that NATS and the CAA remain at the very forefront of SES developments over the coming decade. Their world-class expertise in air traffic management services are second to none in Europe. It is essential that the UK’s high standards are the benchmark to which the SES initiative aspires and delivers.

78. We also require assurances from the Government about certain aspects of the SES initiative.

Network management function

79. A key component of the Single European Sky II (SES II) proposals is the establishment of a “network management function”. It is intended that the function’s main tasks will include:

• ensuring local design solutions are consistent with European network efficiency requirements and that all airspace users can fly optimal trajectories;

• optimising the use of scarce resources (such as frequencies and transponder codes) through a centralised inventory of these resources, with a view to sometimes overcoming conflicting local solutions;

• traffic flow management, slot co-ordination and allocation—to allocate slots as a function of the “required time of arrival” to improve the predictability of operations; and

• management of the deployment of SESAR technologies and the procurement of Europe-wide infrastructure elements.95

Eurocontrol is expected to take on these roles.

80. One of our concerns was that the proposed network management function may have the power to overrule recommendations made by national regulators, such as the CAA. When questioned on this matter, the Director of Air Transport of the European Commission’s Directorate-General for Energy & Transport told us that discussions had not yet reached this level of detail. However, he did not believe that the network management function would be able to overrule national authorities. He told us that the network manager had “functions of co-ordination” but not “decision-making powers in relation to the national authorities”.96 Similarly, the CAA emphasised that the proposed arrangements were strongly focussed on “collaboration and partnership”, and there would

95 Ev 237

96 Q 307

22

be “no infringement” on the vital prerogatives of the UK regulatory system.97 NATS believed that the rule-making framework within the EU meant it would be “highly unlikely we would end up in a conflict where we were forced to do something that we did not think was appropriate”.98 The Minister believed there was “no threat to UK sovereignty within the framework that is being established”.99

81. We accept that a more rationalised European airspace requires a co-ordinating body. It is important to remember, however, that airspace is still subject to national sovereignty. The onus of the network management function should be to work closely with national airspace authorities to ensure they are aware of the wider implications of airspace en-route changes.

82. The Government must be explicit that the focus of the European network management function should be on co-operation, in order to improve efficiency across European airspace. The function should not have the power to overrule recommendations from the national regulator. Such recommendations are firmly based on consultation arrangements with people affected by flight paths.

Extension of EASA’s safety responsibilities

83. The Single European Sky II (SES II) package also includes the objective of establishing a single safety framework for Europe, centred on the European Aviation Safety Agency (EASA), tasked with improving safety levels alongside the increase in air traffic. EASA, established in 2003, has responsibility for setting the regulations and standards for the airworthiness of aircraft, air operations and flight crew licensing. In March 2009, the European Parliament adopted an amending Regulation to extend EASA’s remit to the safety of aerodromes, air navigation services and air traffic management. This means EASA will now establish harmonised rules on air traffic management systems and air navigation services.100 The UK Government supported the legislative proposal.

84. In our October 2006 report on The Work of the CAA, we strongly criticised EASA. We said the fledgling organisation was in a “chaotic state” and “an accident waiting to happen”.101

85. When giving evidence to this inquiry, both the Minister and the CAA said they were satisfied that the UK’s high safety standards would not be compromised by the extension to EASA’s remit. The Minister acknowledged our previous criticisms of EASA, but said the organisation had improved considerably in recent years. The CAA highlighted that one of

97 Q 545

98 Q 346

99 Q 544

100 European Parliament legislative resolution of 25 March 2009 on the proposal for a regulation of the European Parliament and of the Council amending Regulation (EC) No 216/2008 in the field of aerodromes, air traffic management and air navigation services and repealing Council Directive 2006/23/EC (COM(2008)0390 – C6-0251/2008 – 2008/0128(COD).

101 Thirteenth Report of Session 2005–06, HC 809

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the priorities was to ensure EASA obtained the necessary resources to carry out its new functions effectively.102

86. The Committee welcomes the statements made by the Minister and the CAA that the performance by the European Aviation Safety Agency (EASA) has improved. However, the Committee remains concerned that the extension of EASA’s remit may lead to a decline in safety standards and requests the Government and the CAA provide six-monthly reports on progress to this Committee.

SESAR

87. SESAR (Single European Sky Air Traffic Management Research) is the accompanying technology programme of the Single European Sky (SES) legislation. It is a joint European project, mainly industry-led, with the aim of re-engineering the European air traffic management network to become more efficient, better integrated, more cost-efficient and safer. The overall cost of the SESAR programme, set to be implemented in 2016, is estimated at €30 billion (approximately £26 billion)103, most of which will be spent on the implementation of new technologies.104

88. The Ministry of Defence’s Assistant Chief of Air Staff said he had “some questions about the degree of resources” to be invested in the SESAR project. According to 2007 data, the capital contribution of European military users to SESAR amounts to €11.7 billion, most of which is investment into equipment.105 The Assistant Chief also said there would be additional costs for airspace users in the longer-term to adopt the technologies, once it had been developed. He said it would be “a challenge for me and quite likely my successors to ensure that those resources are made available from the Ministry of Defence”.106

89. The CAA should lead work to establish the broad costs and benefits of SESAR for each of the different sections of the UK aviation industry. It should also set out how it intends to improve the phasing of projects within SESAR so as to maximise the benefits to aviation stakeholders most cost-effectively.

6 Conclusion 90. Our inquiry demonstrated that there is much to commend in the current management of UK airspace. The CAA has a global reputation as a respected airspace planner and regulator. NATS is recognised as one of the world’s leading, and most progressive, air navigation service providers. The UK’s airspace safety record is excellent. And, whilst we heard about some of the conflicting demands for the use of airspace, many witnesses affirmed that the current arrangements between civil, military, general and business aviation worked well. Given that the UK has some of the world’s busiest airspace, these

102 Q 547

103 Oanda exchange rate, 1 July 2009

104 “SESAR chief: Airlines ‘key’ to modernising EU airspace” [Interview], Euractiv.com, 25 February 2009, euractiv.com

105 SESAR Consortium , The ATM Target Concept, September 2007, p 74.

106 Q 277

24

achievements must be applauded. Our report aims to build on this strong position through further improvements, such as better communication and consultation with stakeholders.

91. Despite the recent decline in passenger numbers, most industry forecasters believe that demand for air travel will eventually recover to former levels and continue to grow. Indeed, the Government has reiterated its view that its long-term forecasts up to 2030 remain broadly valid. The primary challenge in airspace management is how to maintain the current high standards whilst our and our neighbours’ airspace become even busier over the coming decades and the need for co-ordination and shared practices increases. And, given the Government’s climate change commitments, and the requirements being placed on the aviation industry by the EU Emissions Trading Scheme, the second challenge is how we improve flight efficiency, and thus reduce aircraft fuel burn. These significant challenges must be met, with the top priority always being high standards of safety.

92. Our inquiry highlighted some areas on which to focus over the coming years. Several industry witnesses told us that the development of a strategic “Airspace Master Plan” could offer real benefits in improving the process of UK airspace design. We hope that the Future Airspace Strategy, currently being developed, will facilitate a more systematic and integrated approach to airspace planning in the UK. Proper consultation with stakeholders on the development of the strategy is essential, and should occur sooner rather than later.

93. Efficiency and environmental improvements can also be gained from increased promulgation of new technologies, such as Precision Area Navigation (P–RNAV), and improved air traffic control techniques, such as Continuous Descent Approaches (CDAs). We believe there needs to be a more pro-active, concerted and focussed drive to ensure that the benefits of new technologies and best practice techniques are achieved. And, with more flights forecast in UK airspace, it is crucial to improve the efficiency of the air traffic management system so that Government and the aviation industry meet their respective greenhouse gas requirements. A first step is for the Government to issue revised environmental guidance to the CAA, reflecting current Government thinking on CO₂ and other emissions, and to set out the basic policy principles to which the CAA should adhere when making its airspace design assessments. The Government and CAA must work to ensure that environmental assessments for airspace change proposals use reliable evidence-based criteria.

94. The changes we mention above could largely be made within the next two or three years. But, for the longer-term, the UK’s ability to meet the White Paper growth forecasts will depend on the success of the Single European Sky (SES) initiatives. There will be improvements in the structure of European airspace and new technologies will be developed and implemented, through the SESAR (Single European Sky Air Traffic Management Research) programme. These should have a major impact on the ability of UK and neighbouring airspace to accommodate future growth safely, efficiently, and with minimum environmental impact. It is essential that the UK continue with its leading role within the SES initiatives and SESAR projects to help ensure the delivery of their potential capacity and efficiency benefits over the coming decade.

25

Conclusions and recommendations

The management of airspace

1. Our evidence has demonstrated there is much to commend in the current management of UK airspace. We have been particularly impressed by the technical competence and professionalism of the CAA and NATS. We reject suggestions that responsibility for decision-making about airspace be placed in a different organisation. We see no apparent and significant benefits from such a transfer. (Paragraph 22)

Strategy, change and co-ordination in airspace management

2. It is fundamental that those affected by airspace changes are presented with more than one option, assuming this is possible, during the consultation process. The CAA must encourage airspace change sponsors to follow the guidance requirement for more than one option to be presented, if possible. (Paragraph 27)

3. The CAA and NATS should review the techniques used for designing controlled airspace around airports. The techniques used should match European and USA best practice standards to minimise the impact on general aviation, whilst ensuring safety and that current standards are not lowered. (Paragraph 30)

4. There needs to be clarity about what benefits an Airspace Master Plan would bring, in particular how such a plan would improve flight efficiencies and improve the effectiveness of the Airspace Change Process. (Paragraph 34)

5. When the current project definition stage has been completed, the CAA should present its framework recommendations for a Future Airspace Strategy (FAS) to the Department for Transport and the industry. This work should explain the nature of the FAS, the benefits to be achieved, how the strategy relates to airport development planning processes, and the impact of the strategy on the Airspace Change Process. It should describe the safeguards required to ensure that the FAS does not pre-empt the requirement for proper consultation on airspace change proposals. (Paragraph 35)

6. The CAA could allay many concerns about the perceived slow progress in developing a long-term airspace strategy, and the lack of consultation to date on the FAS, through better communication with stakeholders. The CAA must improve its communication with key stakeholders about the ongoing work on the FAS and the likely timescales. It must ensure that stakeholders are properly consulted about the FAS when appropriate. (Paragraph 38)

7. We believe that airspace impacts should be considered a vital part of airport development proposals. It is essential that National Policy Statements (NPSs) on the development of major airport infrastructure are based on advice from the CAA and NATS about the airspace implications of proposed developments. In the case of non-location specific NPSs, the NPS should include unambiguous guidelines to the

26

Infrastructure Planning Commission on how to evaluate the airspace implications of any proposal. It is vital that the industry is well appraised of the methods used as well as the factors and information used by the Commission in making decisions on major airport developments. (Paragraph 41)

8. Some “stacking” may be inevitable. But excessive stacking, such as frequently occurs at Heathrow, has negative environmental effects. A third runway at Heathrow Airport, if built, offers a real opportunity to add resilience into the air traffic management system and to help reduce excessive stacking. If a third runway is built at Heathrow, the Government should create a framework for setting targets to eliminate excessive stacking around the airport. The CAA should be given responsibility for setting and monitoring such targets. The targets should be included within the relevant National Policy Statement for the development. (Paragraph 45)

9. It is clear that the development and application of new technologies and air traffic management techniques are integral to improving flight efficiency, thus reducing excessive fuel burn, and increasing airspace capacity. (Paragraph 47)

10. We have heard very wide support for Precision Area Navigation (P-RNAV), but a great deal of uncertainty remains amongst industry parties about the actual plans and commitments for the widespread introduction of this technology in the UK. The CAA should produce a strategy for P-RNAV within 12 months. (Paragraph 53)

11. There is currently noticeable variation between airports and between airlines in the take-up of Continuous Descent Approaches (CDA). It is necessary to improve airports’ performance in the use of CDA landings so that the best practice standard is adhered to as near to universally as is achievable. The Civil Aviation Authority must adopt a more active role in encouraging the industry to adopt CDA. The CAA should monitor the CDA performance of major airports and airlines, publish statistics, and promote practices and changes that lead to greater utilisation of CDA. (Paragraph 57)

12. We believe that many concerns from industry stakeholder could be alleviated by improved communication on the part of the CAA. The CAA should review its communication strategy in DAP (Directorate of Airspace Policy) to ensure that policy and technical matters are communicated in a timely and effective manner to all stakeholders. (Paragraph 59)

Environmental impacts of airspace changes

13. Tranquillity is a key factor in sensitive areas such as National Parks and Areas of Outstanding Natural Beauty. Current guidance appears to allow unchequed increases in aviation activity over these areas. Without some level of constraint, the noise environment in these areas might degrade progressively as traffic increases. (Paragraph 64)

14. The DfT and the CAA should examine the case for adopting maximum limits on noise levels and numbers of aircraft permitted per hour over sensitive areas such as National Parks and Areas of Outstanding Natural Beauty. The DfT should fund exploratory research on evidence-based limits. (Paragraph 65)

27

15. The Department for Transport (DfT) should issue up-to-date Environmental Guidance to the CAA before the end of the year. The guidance should represent current Government thinking on CO₂ and other emissions in relation to transport decision-making. The guidance must be clear about the basic policy principles by which the Government expects the CAA to make its airspace assessments. (Paragraph 70)

16. Once the DfT has issued new environmental guidance to the CAA, the CAA must produce clear and comprehensive new guidance on airspace change for the industry. The CAA should adopt a regular review cycle to update the environmental material in the document. (Paragraph 72)

European developments

17. We support the principles of the Single European Sky (SES) initiative to create a more rational organisation of European airspace, for example by establishing cross-border Functional Airspace Blocks. It is unacceptable that, on such a crowded continent, airspace is still largely managed in isolation based on national borders. Greater harmonisation of air traffic management practices at the European level would lead to improvements in efficiency, environmental performance, and capacity. However, it is essential that NATS and the CAA remain at the very forefront of SES developments over the coming decade. Their world-class expertise in air traffic management services are second to none in Europe. It is essential that the UK’s high standards are the benchmark to which the SES initiative aspires and delivers. (Paragraph 77)

18. The Government must be explicit that the focus of the European network management function should be on co-operation, in order to improve efficiency across European airspace. The function should not have the power to overrule recommendations from the national regulator. Such recommendations are firmly based on consultation arrangements with people affected by flight paths. (Paragraph 82)

19. The Committee welcomes the statements made by the Minister and the CAA that the performance by the European Aviation Safety Agency (EASA) has improved. However, the Committee remains concerned that the extension of EASA’s remit may lead to a decline in safety standards and requests the Government and the CAA provide six-monthly reports on progress to this Committee. (Paragraph 86)

20. The CAA should lead work to establish the broad costs and benefits of SESAR for each of the different sections of the UK aviation industry. It should also set out how it intends to improve the phasing of projects within SESAR so as to maximise the benefits to aviation stakeholders most cost-effectively. (Paragraph 89)

28

Formal Minutes

Wednesday 1 July 2009

Members present:

Mrs Louise Ellman, in the Chair

Mr David Clelland Mr Philip Hollobone Mr John Leech Mr Eric Martlew

Mark Pritchard Ms. Angela C. Smith Graham Stringer Mr David Wilshire

Draft Report (The use of airspace), proposed by the Chairman, brought up and read.

Ordered, That the draft Report be read a second time, paragraph by paragraph.

Paragraphs 1 to 94 read and agreed to.

Resolved, That the Report be the Fifth Report of the Committee to the House.

Ordered, That the Chairman make the Report to the House.

Ordered, That embargoed copies of the Report be made available, in accordance with the provisions of standing Order No. 134.

Written evidence was ordered to be reported to the House for printing with the Report.

[Adjourned till Wednesday 8 July at 2.30 pm.

29

Witnesses

Wednesday 21 January 2009 Page

Sir Roy McNulty, Chairman, and Mr John Arscott, Director, Airspace Policy, Civil Aviation Authority

Ev 1

Mr Roger Gardner, Chief Executive, Professor Ian Poll, Cranfield University, Dr Rod Self, Southampton University, and Dr Tom Reynolds, Cambridge University, Omega Academic Partnership

Ev 9

Mr Rob Marshall, President and Chief Executive Officer, Mr Mark Green, Vice President, Policy, Guild of Air Traffic Control Officers (GATCO), Mr Andrew du Boulay, ATM Portfolio Holder for the Air Safety Group, and Mr Rob Gifford, Executive Director, Parliamentary Advisory Council for Transport Safety, Air Safety Group & Parliamentary Advisory Council for Transport Safety

Ev 14

Wednesday 25 February 2009

Mr Tim Johnson, Director, and Ms Laura Simpson, Policy Coordinator, Aviation Environment Federation; Mr Lawrence Wragg, Chairman of Aviation Advisory Group, and Mr Michael Nidd, Technical Adviser to Aviation Advisory Group, Campaign to Protect Rural England; Mr Colin Stanbury, Aviation Adviser, and Councillor Serge Lourie, Leader, London Borough of Richmond upon Thames, 2M Group

Ev 18

Mr Christian Dumas, Head of Sustainable Development and Eco-efficiency, Airbus; Mr Kevin Brown, Vice President and General Manager of Air Traffic Management, The Boeing Company; and Mr Bruno Esposito, Director of Civil Air Transport, Society of British Aerospace Companies (SBAC)

Ev 24

Wednesday 4 March 2009

Captain Dean Plumb, Manager Technical Developments, British Airways, Mr Geoff Clark, Head of Flight Operations Regulatory Affairs, Virgin Atlantic Airways, and Mr Gerry O’Connell, Assistant Director, Safety Operations and Infrastructure, Europe, International Air Transport Association

Ev 31

Air Vice-Marshal Tim Anderson, Assistant Chief of the Air Staff, and Air Commodore Mark Wordley, Director, Defence Airspace and Air Traffic Management, Ministry of Defence

Ev 40

30

Wednesday 18 March 2009

Mr Daniel Calleja-Crespo, Director of Air Transport and Mr Sven Halle, ATM Expert, Directorate-General for Energy and Transport, European Commission; Mr Alex Hendriks, CND Deputy Director for Network Development and Mr Bernard Miaillier, CND Deputy Director for SESAR, Eurocontrol

Ev 46

Mr Ian Hall, Director of Operations, Mr Alex Bristol, General Manager Operational Strategy and Investment, and Mr Lee Boulton, Manager Airspace Delivery, NATS

Ev 57

Wednesday 1 April 2009

Mr Tom Needham, Head of Operations Policy, Airport Operators Association, Mr Tim Hardy, Airside Director, BAA Airport Limited, Mr Paul Kehoe, Chief Executive Officer, Birmingham International Airport Ltd, Mr Richard Gooding, Chief Executive, London City Airport, and Mr Simon Butterworth, Head of Airfield Strategy and Compliance, Manchester Airports Group

Ev 64

Mr Paul Draper, Secretary, General Aviation Alliance; Mr Guy Lachlan, Chief Executive, British Business and General Aviation Association; and Mr John Brady, Vice-Chairman, Light Aircraft Association

Ev 74

Wednesday 22 April 2009

Jim Fitzpatrick MP, Parliamentary Under Secretary of State, Mr Jonathan Moor, Director General of Civil Aviation, and Mr John Parkinson, Head of Airports Policy Division, Department for Transport; Sir Roy McNulty, Chairman, and Mr Mark Swan, Director Airspace Policy, Civil Aviation Authority

Ev 81

List of written evidence

1 Campaign for National Parks Ev 94

2 Mike Andrews and John Sargent Ev 96

3 Little Thurlow Parish Council Ev 96

4 Redhill Aerodrome Limited (RAL) Ev 97

5 Gatwick Area Conservation Campaign Ev 101

6 Manchester Airports Group plc Ev 103

7 Shropshire County Council Ev 107

8 Ministry of Defence (MoD) Ev 108

9 Chiltern Countryside Group Ev 115

31

10 Marilyn M Fletcher BSc PhD Ev 118

11 Ashmansworth Parish Council Ev 122

12 Virgin Atlantic Airways Ltd Ev 123

13 Save our Peace and Quiet (SOPAQ) Ev 126

14 Natural England Ev 128

15 Air Safety Group (ASG) and the Parliamentary Advisory Council for Transport Safety (PACTS)

Ev 130

16 Guild of Air Traffic Control Officers (GATCO) Ev 133

17 The 2M Group Ev 138

18 Great Thurlow Parish Council Ev 139

19 National Trust Ev 140

20 New Forest National Park Authority Ev 144

21 Department for Transport (DfT) Ev 147, 152

22 Chilterns Conservation Board Ev 152

23 International Air Transport Association Ev 157

24 Society of British Aerospace Companies Ev 160

25 Aviation Environment Federation Ev 163, 166

26 Stop Stansted Expansion Ev 169

27 Strategic Aviation Special Interest Group Ev 173

28 The Boeing Company Ev 175

29 National Air Traffic Service (NATS) Ev 176, 181

30 Campaign to Protect Rural England (CPRE) Ev 182, 185, 187

31 London City Airport Ev 188

32 British Airways plc (BA) Ev 192

33 Civil Aviation Authority (CAA) Ev 198, 208, 209

34 Mrs Alastair Robinson, Suffolk Ev 208

35 M I Rushton, Cambridgeshire Ev 210

36 Airport Operators Association (AOA) Ev 210, 216, 217

37 Omega Academic Partnership of UK Universities Ev 218

38 Elizabeth M Balsom Ev 222

39 EUROCONTROL Ev 225

40 British Microlight Aircraft Association Ev 228

41 General Aviation Safety Council (GASCo) Ev 229

42 Airbus UK Ev 230

43 British Parachute Association (BPA) Ev 233

44 BAA Airports Ltd Ev 235

45 European Commission Ev 236, 237

46 British Gliding Association (BGA) Ev 238

47 Birmingham International Airport Ev 245

48 General Aviation Alliance (GAA) and the Light Aircraft Association (LAA)

Ev 247

49 British Business & General Aviation Association Ev 254

32

List of Reports from the Committee during the current Parliament

The reference number of the Government’s response to each Report is printed in brackets after the HC printing number.

Session 2008–09

First Report Work of the Committee in 2007–08 HC 211

Second Report School Travel HC 351 (HC 561)

Third Report Appointment of the Chair of the Office of Rail Regulation

HC 433

Fourth Report The Effects of Adverse Weather Conditions on Travel

HC 328

Fifth Report The Use of Airspace HC 163

Session 2007–08

First Report Galileo: Recent Developments HC 53 (HC 283)

Second Report The London Underground and the Public-Private Partnership Agreements

HC 45 (HC 461)

Third Report Work of the Committee in 2007 HC 248

Fourth Report The future of BAA HC 119 (HC 569)

Fifth Report Ticketing and Concessionary Travel on Public Transport

HC 84 (HC 708)

Sixth Report The Blue Badge Scheme HC 475 (HC 1106)

Seventh Report Department for Transport Annual Report 2007 HC 313 (HC 1102)

Eighth Report Freight Transport HC 249 (HC 1103)

Ninth Report The Draft Marine Navigation Bill HC 709 (HC 1104)

Tenth Report Delivering a sustainable railway: a 30-year strategy for the railways?

HC 219 (HC 1105)

Eleventh Report Ending the Scandal of Complacency: Road Safety beyond 2010

HC 460 (HC 136 & HC 422)

Twelfth Report The opening of Heathrow Terminal 5 HC 543

Session 2006–07

First Report Work of the Committee in 2005–06 HC 226

Second Report The Ports Industry in England and Wales HC 6I-I & 61-II (HC 954)

Third Report Transport for the London 2012 Olympic and Paralympic Games: The Draft Transport Plan

HC 199 (HC 484)

Fourth Report Department for Transport Annual Report 2006 HC 95 (HC 485)

Fifth Report The Government’s Motorcycling Strategy HC 264 (HC 698)

Sixth Report The new National Boatmasters’ Licence HC 320-I & 320-II (HC 1050)

Seventh Report Novice Drivers HC 355-I & 355-II (HC 1051)

Eighth Report Passengers’ Experiences of Air Travel HC 435-I & 435-II (HC 1052)

Ninth Report The draft Local Transport Bill and the Transport Innovation Fund

HC 692-I & 692-II (HC 1053)

33

Session 2005–06

First Report UK Transport Security – preliminary report HC 637

Second Report Financial Protection for Air Travellers: Second Report Abandoning Effective Protection

HC 636 (HC 996)

Third Report Going for Gold: Transport for London’s 2012 Olympic Games

HC 588-I & 588-II (HC 1152)

Fourth Report Departmental Annual Report 2005 HC 684 (HC 1517)

Fifth Report Future of the British Transport Police HC 1070-I & 1070-II (HC 1639)

Sixth Report How fair are the fares? Train fares and ticketing HC 700-1 & 700-II (HC 1640)

Seventh Report Parking Policy and Enforcement HC 748-I & 748-II (HC 1641)

Eighth Report Piracy HC 1026 (HC 1690)

Ninth Report The work of the Department for Transport's Agencies – Driver and Vehicle Operator Group and the Highways Agency

HC 907 (HC 1615)

Tenth Report Roads Policing and Technology: Getting the right balance

HC 975 (HC 290)

Eleventh Report Bus Services across the UK HC 1317 (HC 298)

Twelfth Report Local Transport Planning and Funding HC 1120 (HC 334)

Thirteenth Report The work of the Civil Aviation Authority HC 809 (HC 371)

Fourteenth Report Passenger Rail Franchising HC 1354 (HC 265)

First Special Report The Performance of the London Underground: Government Response to the Committee’s Sixth Report of Session 2004–05

HC 431

Second Special Report

The Departmental Annual Report 2004: Government Response to the Committee’s Fourth Report of Session 2004–05

HC 432

Third Special Report Integrated Transport: the Future of Light Rail and Modern Trams in the UK: Government Response to the Committee’s Tenth Report of session 2004–05

HC 526

Fourth Special Report

Search and Rescue: Government Response to the Committee’s Eighth Report of Session 2004–05

HC 586

Fifth Special Report Rural Railways: Government Response to the Committee’s Fifth Report of Session 2004–05

HC 587

Sixth Special Report Tonnage Tax: Government Response to the Committee’s Second Report of Session 2004–05

HC 611

Seventh Special Report

Financial Protection for Air Travellers: Government and Civil Aviation Authority Responses to the Committee’s Fifteenth Report of Session 2003–04

HC 639

Eighth Special Report

European Community Competence and Transport: Government Response to the Committee's Ninth Report of Session 2004–05

HC 976

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Transport Committee: Evidence Ev 1

Oral evidence

Taken before the Transport Committee

on Wednesday 21 January 2009

Members present

Mrs Louise Ellman, in the Chair

Mr Philip Hollobone Graham StringerMark Pritchard Mr David WilshireMs Angela C Smith Sammy Wilson

Witnesses: Sir Roy McNulty, Chairman, and Mr John Arscott, Director, Airspace Policy, Civil AviationAuthority, gave evidence.

Chairman: Good afternoon, gentlemen. Welcome toour Committee. Do Members have any interests todeclare?Graham Stringer: I am a member of Unite.

Q1 Chairman: Louise Ellman, member of Unite andco-chair of PACTS. Could I ask our witnesses tointroduce themselves and their organisation, please,for our records?Sir Roy McNulty: I am Roy McNulty. I am thechairman of the Civil Aviation Authority.Mr Arscott: I am John Arscott. I am the director ofairspace policy in the CAA.

Q2 Chairman: What do you currently consider to bethe most pressing issues relating to air traYcmanagement and the use of airspace? What wouldyou see as your top priorities to be dealing with?Mr Arscott: At the moment clearly the economiccrisis is something which focuses our attention.Europe is another dimension which we watchcarefully. The environmental issues associated withaviation are clearly high on our agenda. Technologypresents in part some solutions but needs to befocused. Certainly of late the government’s decisionon Heathrow has focused our attention in theairspace area and similarly of course we are workingwith the recommendation of Sir Joseph Pilling’sstrategic review of the CAA and how we mightimplement those recommendations.

Q3 Chairman: What do you see as the mainchallenges for the CAA in relation to these issues?Mr Arscott: Meeting demand in a safe and eYcientmanner.

Q4 Chairman: What would you say is the mostpressing priority and which are the more longerterm ones?Mr Arscott: Safety is the most important thing thatwe have as an obligation and clearly that is front,and centre of what we do. Seeking to ensure thatwhen the economic climate turns up we are preparedto support the return to flying to the same levels aspreviously is one of our greatest challenges and

obviously particularly looking at the airspacecapacity that will be needed in the south east of theUK.

Q5 Chairman: How complex would you say UKairspace is at the moment?Mr Arscott: It is arguably one of the most complex inthe world. It is certainly one of the more complicatedairspaces in Europe but that is not across the wholeof the United Kingdom. Essentially, that wouldapply to the south east of the UK. There are parts ofUK airspace which are relatively straightforward,but there are competing demands from all airspaceusers in all parts of the UK. It is just that they areeasier to solve in some parts of the airspace than inothers.

Q6 Chairman: What would the impact of the thirdrunway be on airspace?Mr Arscott: NATS would have to bring forwardproposals as the air navigation service provider fora redesign of essentially the London TMA and, as aconsequence, probably most of the airspace in thesouth east of the UK. They recognise this; werecognise that. It will be a significant task. We wouldseek to cover all of that in what we have called thefuture airspace strategy, which is an initiative whichwe have jointly taken with NATS and government,to develop for the timescale of the Air TransportWhite Paper—2030, an airspace arrangement for thesouth east which will be compatible with the demandthat we expect at that time.

Q7 Chairman: You gave us written evidence inOctober and at that time you were supporting thelong term growth forecasts in the White Paper,looking at growth in air travel and growth in thenumber of passengers. Do you still remain of thatview?Sir Roy McNulty: We in the CAA do notindependently do long term traYc forecastsourselves. We rely on the forecasts that theDepartment for Transport makes. Myunderstanding is that their current forecast is a bitlower than what they forecast in 2003, but it is not

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radically lower. Certainly they are forecasting traYcfor 2030 very much higher than the traYc levels thatwe have today.

Q8 Chairman: You feel confident that, despite theeconomic circumstances now, the growth will stillbe there?Sir Roy McNulty: I think that is the most reasonablebasis on which to plan. We have had 30 years’experience that shows how traYc grows as economicgrowth goes in parallel. I do not think we should beplanning on the basis that this recession is going tobe our permanent condition. I think we have to planin the expectation that some degree of economicprosperity and growth will return. That being so, weneed to cater and plan ahead to have the capacity todeal with increased traYc.

Q9 Chairman: Is this a hope or is it based onanything substantial?Sir Roy McNulty: That, to me, is the most realisticscenario to plan on based on all the experience wehave had to date.

Q10 Chairman: You mentioned the Pilling Report.One of the recommendations there was that youshould have more specific responsibility forenvironmental issues. Do you think that would behelpful and when are you expecting to hear moreabout that?Sir Roy McNulty: We do think it would be helpful.I think it recognises today’s realities and priorities.We are currently in discussion with the Departmentfor Transport around that area and we would expect,during the next few months, to reach someconclusions on what that environmental duty shouldlook like. Obviously in recent times we have had a lotof discussion with them around the Heathrowsubject, but I think a broader environmental dutywould make sense to us and probably makes sense tothe Department for Transport.

Q11 Mr Wilshire: I want to see if I can resist thetemptation to get involved in Heathrow at themoment. I think that is a matter for NATS. If Iremember rightly, Sir Roy, last time you were here onthe report that we did on you, we got onto the subjectof the Single European Sky and we ended up havingsome concerns. We discussed with you that there wasa danger, if we were not careful, of levelling downstandards rather than levelling up. That was ourview, not yours. I am not trying to put words in yourmouth. We now have proposals for the future. Couldyou tell us whether some of the fears of the past thatyou and others have expressed have come about?Have there been diYculties with single Europeanskies mark one? Will mark two that is now beingconsulted on solve any of those problems and makesome improvements?Sir Roy McNulty: To date we have seen no evidencethat standards get levelled down. That relates bothto the Single European Sky and to EASA, theEuropean Aviation Safety Agency. There is a riskthat that could happen. We work extremely hard andwe are putting a lot of time into dialogue with people

in Europe. We work very closely with theDepartment for Transport and to date I would saywe have been successful in getting agreed outcomesacross Europe which do not threaten the standardsthat we have here. Looking ahead on SingleEuropean Sky, it is a major challenge in one sense. Alot of change, both organisationally, institutionallyand in terms of regulation and technology, isenvisaged. That will be a challenge to dosuccessfully, but it is very important that it issuccessful because, in terms of dealing with futuretraYc growth, coordination and working together inEurope is fundamentally necessary.

Q12 Mr Wilshire: But you will be keeping as close aneye on mark two as you did on mark one to makesure we are not being asked to reduce our standards?Sir Roy McNulty: I think we will keep an even closereye on mark two because the risks are greater. Tothat extent, it requires greater attention, greaterthought and more hard work from everybody.

Q13 Mr Wilshire: You said in reply to my firstquestion that you knew of no evidence that the firstversion had caused any lowering in standards. Iassume that you have looked very, very hard forevidence and failed to find it rather than it justhaving passed over your desk?Sir Roy McNulty: We look in great detail—somepeople would say to the point of tedium—at everyelement of what is put on the table as proposals, bothfrom EASA and from the Single European Sky. Wesatisfy ourselves that there is nothing in it that willbe harmful to UK interests, both in terms of safetystandards, in terms of the eYciency of our systemand so on.

Q14 Mr Wilshire: With mark two, where if anywhereare there going to be concerns? What are the issueswe ought to focus on to ensure that our standardsstay as high as they are?Sir Roy McNulty: With Single Sky mark two,perhaps there are two I would highlight. One isdealing with the institutional complexity in Europe.As I am sure you are well aware, there are many,many diVerent bodies involved. Getting them all tohead in one direction simultaneously is quite achallenge, bearing in mind there are 27 diVerentcountries that have to make the same changes at thesame time to make this programme eVective. That isone big challenge. The second big challenge relatesto technological innovation. Within the Single Skytwo programme is SESAR, which is a major stepforward to the next generation of air traYc controlsystems. We believe that is a necessary step but, as weknow ourselves the hard way, major steps forward intechnology are not without risk and usually notwithout pain. I think that will require a great deal ofattention.

Q15 Mr Wilshire: Having talked for a moment ortwo about the safety issues of the Single EuropeanSky, can I ask about availability? Will mark two

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make it easier or more diYcult for us to get a goodallocation of available airspace? Is it going to intrudeupon our ability to allocate our own space?Mr Arscott: No. I think it is important to make thediVerentiation between the EASA safety activitywhich is in one part of the Commission and theSingle Sky arrangements which are in a diVerentpart. An important component of the Single Sky twopackage will be a performance regime with targetsset at a European level. The whole purpose of that isto try to ensure that state arrangements do not standin the way of European eYciency. The PerformanceReview Commission of Eurocontrol, of which I ama member, is focused on producing a performancepackage for endorsement and enforcement by theCommission which will, I am fairly confident, makethe passage of aircraft across Europe morestraightforward and reduce delays. It will of coursedepend on the sovereign states to comply with andcontribute to that European basis.

Q16 Sammy Wilson: In relation to the third runwayat Heathrow, are the air traYc implications ofincreasing the capacity of Heathrow any diVerentthan if the availability of extra runways in the southeast of England being provided elsewhere wouldhave for air traYc control, or does it really matterwhether it is in the estuary or at Heathrow what theimplications for air traYc in the south east ofEngland would be?Mr Arscott: Almost irrespective of where anadditional runway was provided in the south east, awhole scale review of the airspace arrangements isgoing to be necessary, if you are starting not with aclean sheet of paper, because you never can do thatin air traYc control, but you at least have the optionsfreely available to you to configure things in a moreeYcient manner and our future airspace strategywork, which can now proceed apace now thedecision has been taken on where that runway will bewill be, focused principally on that objective ofsecuring that we get eYciency, which is the onlycommon ground really between aviation and theenvironmental interests; that we reduce delays, thatwe recognise, as my Chairman said, that the SESARproject which will cover all European ATM in thefuture is properly recognised and crucially thesovereign obligations of states are properlyrecognised. Although it is a future airspace strategyfor the United Kingdom, it will by definition expandover a great deal of Europe. Some of the initiativeswhich came from Single Sky one like functionalairspace blocks will facilitate that sort of debate.

Q17 Sammy Wilson: Given the fact therefore thatwhatever you do is going to have environmentalimplications in terms of stacking, in terms oftrajectory for planes landing, taking oV, etc., why isthere a need for a specific environmental remit? Byimplication, any change that you make to improveair traYc and the use of airspace are going to havean environmental impact anyway. Why the need fora specific guidance from an environmental point ofview?

Mr Arscott: At the moment, the statutory dutywhich the CAA has for the performance of its airnavigation functions talks about, in addition tosafety, securing the eYcient use of airspace andmeeting the needs of airspace users, but only takingaccount of the environmental impact of aviation.Many would argue that that is not the right balancefor the current regime and that we should have astronger remit to take account of and mitigate theeVects of aviation than we currently have. That is thereason we support Sir Joseph’s recommendationthat we should have a statutory duty, but it is quiteclear that the context of that statutory duty has to bewithin a clear policy framework and needs to notconflict with the other statutory duties that we mighthave. That is quite a big ask for government and itis essential that we are given that statutory dutywhich is, frankly, doable and does not conflict withmeeting airspace users’ needs whilst doingsomething for the environment. That is the reasonthat we feel a strengthening of the environmentalstatutory duty would be beneficial and wouldrecognise the feelings of society towards aviation atthe moment.

Q18 Sammy Wilson: Is the danger of that not that,from an environmentalist’s point of view, they willalways see that, whatever decisions you make,whatever recommendations you make and actionsyou decide on, you will always be in favour of the useof aeroplanes and they are against that. Therefore,even by giving you that remit, you are probably notgoing to satisfy the people who are objecting to airtravel per se.Mr Arscott: You are right of course but I think thereis a range of environmental interests which rangefrom what you describe to people who acknowledgethat society wants to be able to fly and that it is amatter of how you accommodate flying in the mostenvironmentally sustainable manner. My feeling isthat the majority of the environmental interestgroups are more perhaps towards the fact thatpeople are going to want to fly and we need to do itin an environmentally sustainable way than the factthat we leave the aeroplanes in a hangar andeverybody goes by train or walks.

Q19 Graham Stringer: I hear what you say but I amfinding it diYcult to imagine what would be diVerentif you had this power. You would not be changingthe European environmental limits on noise, forinstance, would you? You would not be changing theloud noise controls round airports, or would you?Mr Arscott: Unlikely.

Q20 Graham Stringer: What would you be changingif you were given this environmental remit? You say,“We want this environmental remit because itsounds good but it will not aVect anything else weare doing.” I want to know what it will aVect. Whatwill change if you get this responsibility?Mr Arscott: It could put constraints on the air traYcoperation. For example, it may be that only inexceptional circumstances will there be holding.Only in exceptional circumstances would there be

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more than two aeroplanes in a hold. What you wantis something which incentivises technologicaldevelopments to enable you to operate aircraft in amuch more eYcient manner from an environmentalviewpoint. It could well be that, unless for examplean aircraft has free passage to the ramp at the arrivalairfield and can unload the passengers and switch theengines oV, it does not get start clearance at the pointof departure. That is the sort of obligation that thegovernment I am sure will think about giving us. Wewould just be concerned that it will be consistentwith using the air traYc management system in aneYcient manner.Sir Roy McNulty: This environmental duty which isenvisaged for the CAA would be a general duty thatapplies to all of the things the CAA does, not just inairspace. For example, in carrying out our duties aseconomic regulators of airports, at the moment thereis nothing in the statute that says the economicregulation part of the CAA should take accountnecessarily of environmentalists’ expenditures toimprove the environmental performance around anairport. If we had that general, environmental duty,that is something that the economic regulation partof the CAA would take into account in doing itswork.

Q21 Graham Stringer: Can I ask you the samequestion in terms of the noise round an airport or thenitrogen oxide levels? Would you be changing thoseand having higher standards than those that werepreviously set, particularly where there areEuropean standards?Sir Roy McNulty: Not necessarily. I think theexample that springs to my mind most obviously isthat, at the moment, the duties we have as economicregulators are focused on cost eYciency and theprovision of services to passengers. They do not callin, so to speak, environmental considerations. Thepurpose of having this environmental duty is tomake sure that all parts of the CAA have thatgeneral duty and that the environmental aspects areto be taken account of in setting prices for airports.

Q22 Graham Stringer: I can see for completenessthat it is important. What I am trying to get to iswhat would change. One of the biggest impacts, ifnot the biggest impact, at airports is in roadtransport to the airport in terms of cars and lorriesarriving at the airport. Would you be looking at thecapacity in the road system and those kinds ofenvironmental things beyond what the HighwaysAgency and the Department for Transport aredoing?Sir Roy McNulty: We might be looking atcontributions towards improving surface access forenvironmental reasons which again, under ourcurrent remit, it is arguable we might not take intoaccount.

Q23 Graham Stringer: Would you not be duplicatingwhat is done by other agencies of government?Sir Roy McNulty: We would naturally be focusingon the airport and services that feed into the airport.In previous exercises, we have allowed expenditures

on Heathrow Express and things like that whichobviously have a transport benefit but also have anenvironmental benefit. The purpose of theenvironmental duty is to make it clear in thehierarchy of tasks that the CAA is given that theenvironmental dimension is important.

Q24 Graham Stringer: We can all agree on that. I amjust trying to find out where you would change theworld as opposed to it being just a nice line in a remit.Sir Roy McNulty: I think this is still work inprogress. We see the environmental duty on the CAAsitting within a clear environmental policyframework established by government relative toaviation. It is arguable that that does not exist today.There are clearly now targets for emissions overallby 2050 and probably intermediate targets.Eventually, those will translate into targets foraviation and I think the CAA will be part of themechanism whereby those targets get delivered.

Q25 Graham Stringer: Mr Arscott, if I can take youback to stacking, you clearly would not apply that toHeathrow in its current situation. You would notsay, “You cannot stack at Heathrow”; otherwise,you would reduce the capacity of Heathrow by quitea lot, would you not?Mr Arscott: It is most unlikely in the currentenvironment. I think we need an incentive toimprove the technology that might allow us to dothat.

Q26 Graham Stringer: Where would you apply it?What would be the consequences? If you are notallowing aeroplanes to stack, they have to gosomewhere else, do they not?Mr Arscott: Not necessarily. This is all part of whatwe envisage being undertaken in our future airspacestrategy work. We want to see the technology and weare confident it can be developed, particularly if it isincentivised, that would enable aircraft not to takeoV until there was an optimal level—

Q27 Graham Stringer: At the moment I am withlanding aircraft. The point you make about takingoV is very sensible. I cannot understand whyaeroplanes start their engines before they are readyto go. If aeroplanes are coming in and you say thatat that airport they cannot stack, they are going tohave to go somewhere else, are they not, withconsequences in the fuel bill?Mr Arscott: No, I do not agree at all. They do nothave to go somewhere else. If you have thetechnology—and we are not that far oV—whichwould enable an aircraft to take oV and fly on anoptimum profile to a final approach to a runway,land and get on a stand and shut the engine down,you do not have to stack. All of that is a componentof the future airspace strategy and how we mightachieve that, but it is not unachievable in areasonable timescale that we are talking about forthe delivery of the Air Transport White Paper.

Q28 Mark Pritchard: How do crowded airspace andregional airports fit in—for example, Birmingham?

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Mr Arscott: They are an increasing component ofthe air traYc mix in this country. The diYculties ofgoing through Heathrow have meant that a lot ofregional airports have grown in capacity over thelast two years, rightly so. In one respect, it presentsus with some opportunities in that, if they are awayfrom the south east of the UK, it gives us somerouting opportunities to take them to the continent,north America or something like that withoutgoing through the south and south east.Alternatively of course, if they are in the mainlandUK, Scotland, Northern Ireland and Wales, andthey want to get to Europe, then it is quite diYcultto do that without going through the south east ofthe UK. The option it gives you is to transit thesouth east of the United Kingdom at higher levelsthan you would transit if you had taken oV fromthe south east. Regional airports do have a greatutility and are popular with the public. Weencourage their use and we facilitate the airspacearrangements to enable them to operate eYciently.The environmental impact at regional airports is inmany respects less for the same given aeroplanethan you would find if it was in congested airspacein the south east.

Q29 Mark Pritchard: Do you think extendingBirmingham’s runway would help or hinder thestrategy that you are trying to make?Mr Arscott: That was one of the components of theAir Transport White Paper, to do that. Acomponent was to have another runway which Ithink has rather diminished now. The extension sothat you can operate larger aeroplanes for longerhaul is something that would need to be factoredin in our airspace strategy. We do not see any hugeproblem associated with that.

Q30 Mark Pritchard: Would that extension help orhinder the strategy you want to implement?Mr Arscott: I could not say either way.

Q31 Mark Pritchard: You used the words “factoredin”. What does “factored in” mean? Is it factoredin positively or negatively?Sir Roy McNulty: It is taken account of.

Q32 Mark Pritchard: Have you taken account of it?Sir Roy McNulty: We will. This future airspacestrategy—

Q33 Mark Pritchard: Do you have an interim viewon the account that you have taken thus far or thatyou might take?Sir Roy McNulty: We have not got to that stage.NATS are doing work on scoping exactly how thisexercise should be done, how big it is and so on. Itis probably an exercise that will take us another twoor three years to complete.

Q34 Mark Pritchard: Again, back to crowdedairspace, increased use of unmanned air vehicles formilitary purposes, mapping, intelligence gathering.How much of an issue are UAVs within domesticairspace?

Mr Arscott: They are significant. I think it is fairto say we are in the lead in Europe, if not the world,in facilitating access to UAVs into what iscommonly called civil airspace. In fact, thismorning at the board we took a presentation fromBritish Aerospace Systems on exactly this point.The most challenging area for unmanned airsystems is outside controlled airspace whereessentially separation is provided by the pilot seeingand avoiding conflicting aeroplanes. We translatethat into unmanned air systems as a sense andavoid as opposed to see and avoid. Getting thetechnology around a sense and avoid system is areally challenging exercise. In the controlledairspace environment, arguably, the solution iseasier to come by because you have a much moreorganised system and you can specify theelectronics on an unmanned system as you wouldfor an airliner. Broadly speaking, it is a more simpleoperation. We have some experience of doing thatwith unmanned air systems flying through and intoUK airspace already.

Q35 Mark Pritchard: Whether in or outsidecontrolled airspace, are you aware of anyunmanned aerial vehicles that are currently beingpiloted by pilots who are not resident within theUnited Kingdom?Mr Arscott: I do not think so. We have had someaircraft fly through UK airspace which areeVectively being controlled from outside the UKbut of course under the authority of the air traYccontrol system in the United Kingdom. That isperfectly normal.

Q36 Mark Pritchard: How many near misses havethere been in the last 12 months betweencommercial aircraft and UAVs?Mr Arscott: None that I am aware of.Sir Roy McNulty: None that I am aware of either.

Q37 Mark Pritchard: You would be aware of it ifthere had been?Sir Roy McNulty: Absolutely.

Q38 Mark Pritchard: You mentioned earlier thattechnology does not come without risk. In this dayand age where we are going to have more and moretechnology, cyber security and people trying topenetrate systems just for fun—some peopleperhaps for geopolitical reasons—how secure doyou think the United Kingdom air traYc controlsystems are? How confident are you that they aresecure, robust and resilient against maliciouscyber attack?Mr Arscott: Were they to be interfered with, thatwould be a safety issue and we have a robust andresilient system for reporting safety incidents. It isone of the benefits of the aviation industry in thiscountry that we have a full and frank, openreporting system which encourages the reporting ofsafety incidents for the benefit of the industry as awhole. We have very few examples of what you aresuggesting. On the few occasions that there havebeen, the courts and the police have acted very

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quickly and vigorously. You will be aware that wehad some issues before Christmas on lasers whichresulted in people being imprisoned. That sent avery powerful signal about the sorts of things thatwe have but, as with all aircraft and air traYcsystems designs, their resilience to electronicinterference is part of the certification of thesystem. I would expect that to continue in thefuture. The industry is well aware of the potentialthat you allude to and I am certain that in thefuture it will need to be suYciently mitigated sothat safety is not adversely aVected.

Q39 Ms Smith: I just wanted to go back to thestacking issue. It is the case, is it not, that there isa stacking problem at the moment at UK airports?Mr Arscott: A problem is rather overstating it.

Q40 Ms Smith: It happens?Sir Roy McNulty: It is standard practice.Mr Arscott: As Mr Stringer said, if you want tooperate a runway at maximum capacity, at themoment with the current available technology thebest way to achieve that is to have a ready pool ofaircraft that the air traYc controller can pull oV atwill to ensure that the minimum separation ismaintained in getting maximum runway capacity.It is a routine way of optimising runway capacity.Problems occur which are resolved by stacking asa consequence of bad weather, uncerviceability,aircraft, ground systems and a whole myriad ofthings of which I am sure you are aware. Stackingis a proper practice for air traYc control in thecurrent era.

Q41 Ms Smith: In environmental terms it can beseen as a problem.Mr Arscott: It is certainly an environmental issue.

Q42 Ms Smith: The technology you describepotentially to deal with this has been a long timein the development. How confident are you that itwill be ready in the foreseeable future?Sir Roy McNulty: As I said earlier, this is a major,major programme of research and technologicaldevelopment for the next 20 years. How confidentam I? Scared rigid might be the phrase. This is verychallenging but very necessary. It will deliver majorbenefits in terms of cost eYciency, in terms ofenvironmental performance but, as we know, bigcomplicated technological leaps forward are full ofrisks and need to be managed very carefully.

Q43 Ms Smith: It has been, as I understand it,about 30 years so far in the development.Sir Roy McNulty: No. The SESAR programme isreally only being launched now. This is the next bigstep. In the United States they have a quite similarprogramme called “NextGen”, next generation.This is the next big step ahead for the air traYccontrol system that we know and love and whichhas been much the same for the last 20 to 30 years.

Q44 Ms Smith: No clear timescale. I understandthat. You seem to have some confidence that aprogramme of this kind will be implemented.Sir Roy McNulty: A programme of this kind,managed very well and done step by step, shouldbe able to be delivered. It needs a research phasein many cases to prove the concept and then we goahead with the implementation.

Q45 Ms Smith: Is it not the case that, even giventhe development of technology such as this, carefulplanning for potential increases in use of airspaceneeds to be built in in order to make suchtechnology work properly? In other words, if youget the planning wrong, it does not matter howgood your system is for managing landings ofaircraft at airports, you will still have a stackingarrangement.Sir Roy McNulty: One of the objectives of thissystem will be to make the whole planning andexecution of any given flight a much more preciseoperation. At the moment it is not so precise. Thetimings are not so precise. The handing of aircraftfrom one controller to the next controller fromsector to sector is not a very precise exercise. Whatis envisaged under SESAR is much more precisetiming and coordination between all the flights thatare going on at any one time.

Q46 Ms Smith: What I was trying to say though isthat it is not just that, is it? It is about how muchcapacity you have in terms of runways and so onin order to land the craft in the first place. It doesnot matter how good your technology is, you stillneed runways to land on so careful planning ofairspace use and capacity for landing craft are stillmajor issues.Sir Roy McNulty: Absolutely. The whole systemhas to work together.

Q47 Ms Smith: On safety, the potential increase inuse of airspace has to be planned for of course butcan you reassure me that the strategy will take anyextra measures necessary to maintain safetystandards?Sir Roy McNulty: Absolutely.

Q48 Ms Smith: Are there any extra measuresplanned?Sir Roy McNulty: We are taking measurescontinuously. Just to go back to the Transport Act2000 which set up the airspace policy activity withinthe CAA, it was made crystal clear in thatlegislation that safety was paramount. That is thefirst and major duty on the CAA. We work onsafety aspects all the time. Everything that theAirspace Policy Group does in terms of airspacechanges or other things is done in very closecoordination with our safety regulation people. Wedo not take steps that we are not satisfied are safe.We have a series of programmes. At the momentwe have an airspace safety initiative which isparticularly looking at safety issues in uncontrolledairspace and where the junction betweenuncontrolled and controlled airspace happens. That

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is an exercise we are doing in close cooperation withNATS, with the Ministry of Defence, with generalaviation interests, with the whole aviationcommunity and getting excellent cooperation indoing so. All of these people are wanting to see asafe system and are dedicated to working with us.

Q49 Mr Wilshire: A topical issue which I think ishighly relevant to the general question of futurecapacity is bird strikes. These are horribly topicaljust at the minute. I assume that that risk figureswhen you are doing an overall assessment of safetyin air traYc control?Mr Arscott: Yes. It is one of the many things whichare considered. A safety case for an airspace changehas to be produced, scrutinised by on the one partthe safety regulation group of the CAA and on theother part, if there is a military connection, by theMinistry of Defence. They assure us that the safetyis suYciently rigorous to enable that arrangementto be put in place. Specifically on bird strikes, if youwant, I can explain what we do. I do not knownecessarily that you have the time or inclination tohear about that.Chairman: If you want to send us more informationthat would be helpful but we will carry on with thequestions.

Q50 Mr Wilshire: Could I pursue the general issueof bird strikes? Would it be reasonable to assumethat some areas are at greater risk than others whenit comes to assessing bird strikes?Mr Arscott: Yes. We identify those by a number ofmeans with the assistance of the RSPB and peoplelike that. They are marked on charts. There arecertain statutory duties that operators of aircraft,people who run airports, local authorities, DfThave as an obligation to notify those areas andpilots of course are expected to react in a mannerthat we describe in the ANO in those areas, theobjective of course being to minimise the possibilityof something like happened in New York.

Q51 Mr Wilshire: Would you discourage me fromthinking that salt marshes and coasts probablyhave a greater capacity for producing large birdsthan some inland sites?Mr Arscott: No. That is exactly what we have saidon the proposal in the Air Transport White Paperfor an airport at CliVe.

Q52 Mr Wilshire: That still remains the case?Mr Arscott: Absolutely.

Q53 Mr Wilshire: You have the impossible task ofsatisfying three competing interests, military,general and civil aviation, all of whom will nodoubt tell you that you are being unfair to them.Is the attempt to find more capacity now for civilaviation going to be at the expense of militaryactivities and general aviation or can you cope withthat pressure?Mr Arscott: The whole exercise is a balancing act.Depending on what the government policy on therequirement is, that tends to direct us in fulfilling

what we believe to be the public interest. Forexample, in the south east of the UK where youhave a large number of airports and a lot of intensecommercial air traYc it is a challenge to havegeneral aviation and the military working in thoseareas. What we need to do is to give them areas,particularly for the MoD, where they can carry outwhat they need to do but not necessarily in thatportion where it conflicts with commercial airtransport. General aviation is more of a challengein that the opportunity to go further afield is lessfor them, obviously because of residents and theability to fly long distances quickly, but we do seekto make most of our airspace arrangementsinteroperable between the interests that youdescribe. Technology enables us to do that mosteYciently. We have a number of initiatives whichpermit interoperability of disparate activities likefor example the mandatory carriage oftransponders which gives every aeroplane or everyair vehicle an electronic signature, which means ofcourse that safety nets and safety systems can thenbe eVective and augment the see and avoidprinciples in uncontrolled airspace that I described.In an airspace which is as congested as the UnitedKingdom, I measure success on the grounds that,if the level of abuse from the three interest groupsthat you describe is about the same volume, thenwe probably have it right. If somebody rings meand says, “That was a really good decision” almostcertainly we have got it wrong.

Q54 Mark Pritchard: All three generate noise ofcourse and I just wonder if there is a technical term.In some airports, in some countries, the rate ofdescent is very rapid so aircraft are kept pretty highand they descend at a rate of knots from a fargreater height. What is the name for that?Mr Arscott: It is continuous descent approach.

Q55 Mark Pritchard: Given that we see aircraftcoming in on the approach, maybe 10 or 15 aircraftat a time higher than one another flying overLondon, disrupting lives sometimes, why are wenot using that mechanism more often?Mr Arscott: What you describe is not actuallycontinuous descent approach. The steep approachis what we operate at London City Airport becauseof the obstruction criteria around the airport. Itwas originally operated as a short take oV andlanding airport and that is the configuration of theaircraft that fly in to it. It so happens that otheraircraft now can use that configuration but thereare—

Q56 Mark Pritchard: With the short take oV andlanding, that is on take oV and landing bydefinition, talking about the length of the runway,not the rate of descent.Mr Arscott: Not so in as much as the flatter theapproach almost certainly the longer the run isgoing to be; whereas a steep approach invariablyallows for a much shorter landing run, which is whythe military and others use that technique. Thecontinuous descent approach is not about steep

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approaches. It is about commencing the descent atrange and continuing the descent uninterruptedsuch that you do not have the noise disadvantageof increasing the power of the engines because youhave to maintain level flight, eVectively cleaning upthe aeroplane. You therefore have a much lowernoise profile if you can operate continuous descentapproaches.

Q57 Mark Pritchard: I realise that is where youwant to get to but where we are is that there is forsome people a lot of noise. I just wonder why, giventhat the runways are longer at City Airport andHeathrow, we are not seeing a steeper descent inorder to avoid noise.Mr Arscott: Operationally, it produces disbenefitswhich are not—

Q58 Mark Pritchard: What about the introductionof new technology? You are raving about newtechnology here and interoperability between steepdescent and new technology.Mr Arscott: It is certainly an option that wouldneed to be considered but you get a more accuratelanding if you have made a slightly lower—

Q59 Mark Pritchard: What is the definition of“accurate landing”?Mr Arscott: It enables you to land precisely andtherefore meet the fast turn oV that you want soyou can improve the runway capacity. We need tobe clear: continuous descent approaches aresomething that we advocate, we mandate and,generally speaking, are operated widely in theUnited Kingdom. We would like to see more of itundoubtedly and we seek to achieve that in thetechnology development and certainly in the futureairspace strategy that I have described.

Q60 Mark Pritchard: I may be wrong here but afterthe New York incident, the bird strike and theaircraft that landed in Hudson Bay, I was watchinga TV programme and a UK pilot said, “We do nottrain for water landings.” I was not quite sureabout that. I thought surely, given that we are anisland, there is practice for emergency landings onwater which is standard in the United States. Whatis the position?Sir Roy McNulty: Pilot training, done on a threeyear rolling programme for each pilot, does coverall sorts of emergency procedures. We can give youa separate note on that.

Q61 Mark Pritchard: Do you know if it includeslanding on water?Sir Roy McNulty: From memory, it covers thecheck lists and everything that you would need forsuch a situation.

Q62 Mark Pritchard: With the proliferation of bothland based and oVshore wind farms, how does thataVect your business and in particular impact onradar, disruption to radar, misinformation as aresult of disruption, etc?

Mr Arscott: Very significantly. The physicalobstruction of the wind turbine can be mitigatedadequately by lighting and operational proceduresand safeguard zones around airports. The eVectthat moving turbines have on primary radar is verysignificant. It is much less so with secondary radar,which is where there is a transponder in the aircraftwhich responds to an interrogation from theground. That is another reason why, for the airtraYc community, we want to move towardstransponder carriage by everybody so that we aregoing to give a free hand, pretty well, to the windpower industry to go ahead and develop theirturbines. In the CAA, I am a member of BERR,now DECC, aviation management board. We havean aviation programme which is sponsored by thePrime Minister to seek to enable the government’srenewable energy targets to be met. We are doinga lot of work on how that and the problems youallude to, can be resolved. Technology isundoubtedly a possibility but certainly we havetaken the role of seeking to facilitate solutionsbetween aviation and the wind power industry inthe vicinity of airports by suggesting diVerentoperational procedures and diVerent locations forthe building of these turbines. Over the next yearor so, we will probably see some quite usefuldevelopments on that. Your view that theyinterrupt air traYc control radar at the moment isabsolutely correct.

Q63 Sammy Wilson: What kind of area are youtalking about or what kind of distance from theairport?Mr Arscott: It is diYcult to say because it dependson the type of radar. Generally speaking, anythingwhich is within about I suppose 30 kilometres of aradar is probably going to cause some problem.The Ministry of Defence, who I think havesubmitted a memorandum and may wish to answerthis point as well, have significantly greaterproblems than does the civil air traYc communityon this point, but they are involved with thisinitiative with BERR and DECC. I think we aremaking progress even for the MoD but obviouslythey would wish to speak for themselves.

Q64 Graham Stringer: With the advancingtechnology, what is the likelihood of the statutoryminimum distances between aeroplanes beingreduced or between runways? Are either of thoseminimum distances likely to be reduced?Mr Arscott: We hope that that would be the casebut clearly there would have to be a safety caseproduced and sustained to prove it.

Q65 Graham Stringer: Over what period of time? Isthe technology there to reduce the distance betweenplanes now?Mr Arscott: There are certain circumstances wherethe separation distances can be reduced already. Ifthat was more widely available supported by asafety case, we would be keen to see it.

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Q66 Graham Stringer: In terms of the technologywe have at the moment, what would that do to theincreasing capacity at Heathrow?Mr Arscott: Since the limiting factor is runwaycapacity, nothing.

Q67 Graham Stringer: I do not understand that. Ido not know what the minimum distance is at themoment, but say it is three miles, if you were toreduce it to two miles you could presumably runmore aeroplanes.Mr Arscott: It depends how close you can havethem on the runway. I thought you were talkingabout separation in the air.

Q68 Graham Stringer: I was talking about twothings. I was talking about the separation ofaeroplanes in the air and landing, so that you couldget more coming in, and, quite separate from that,I was talking about the physical separation betweenrunways, not planes on runways.Mr Arscott: To take the two points: the separationof aircraft on final approach is determined by theseparation that is acceptable on the runway. Theseparation between runways is occasioned by theaccuracy of the navigation systems on the aircraftand on the ground to ensure that there are nocircumstances under which for runways which areclose together the operation on one will aVectadversely the operation on the other.

Q69 Graham Stringer: Presumably, if you could getthem closer together you would increase thecapacity.

Witnesses: Mr Roger Gardner, Chief Executive, Professor Ian Poll, Cranfield University, Dr Rod Self,Southampton University, and Dr Tom Reynolds, Cambridge University, Omega Academic Partnership, gaveevidence.

Q75 Chairman: Good afternoon, gentlemen. Wouldyou introduce yourselves and your organisations forour record, please.Dr Reynolds: Good afternoon. My name is TomReynolds. I am with the Institute for AviationEnvironment at the University of Cambridge.Dr Self: My name is Rod Self. I am at the Instituteof Sound and Vibration Research at the Universityof Southampton.Professor Poll: I am Ian Poll. I am Professor ofAerospace Engineering at Cranfield University andTechnology Lead in the Omega Programme.Mr Gardner: I am Roger Gardner, Chief Executiveof the Omega Knowledge Transfer Partnershipbased out of Manchester Met University.

Q76 Chairman: Thank you very much. What are themain findings of your work examining ineYcienciesin traYc management?Mr Gardner: The partnership has addressed a rangeof diVerent issues, of which this is one. The expertwho has done the majority of work in this area is Dr

Mr Arscott: Both what together?

Q70 Graham Stringer: If you were to get theaeroplanes closer together on the runway and in theair, you would be increasing the capacity, wouldyou not?Mr Arscott: If you could have a shorter landingsequence, yes.

Q71 Graham Stringer: Is the technology there to beable to do that?Mr Arscott: No, not at present.

Q72 Graham Stringer: Is it likely to be in thefuture?Mr Arscott: I would have thought it would be anobjective of the industry to do that, for obviousreasons.

Q73 Graham Stringer: Is there a time horizon forthat?Mr Arscott: Not that I am aware of.

Q74 Graham Stringer: The distance betweenrunways?Mr Arscott: I am not aware at the moment. Thereare International Civil Aviation Organisationcriteria for this which have been reasonably robustover time. I am not aware that there is anyparticular technology being developed now whichwould facilitate runways being closer than theminimum specified under ICAO arrangements atthe moment.Graham Stringer: Thank you.Chairman: Thank you very much for answering ourquestions.

Tom Reynolds, so he is probably best placed toanswer the specifics on that particular element of ourprogramme of work.Dr Reynolds: Very much in the same vein as we heardfrom the CAA when they were talking about thetechnology, they referred to the fact that, with theplanned advance technologies that are beingdeveloped now, both in Europe and the US, weshould be able to get closer to the ideal trajectorythat all aircraft could fly if there were no otherconstraints imposed upon them by the air traYcmanagement (ATM) system. If there were only oneaircraft in the sky and there were no constraints onit, it could fly an environmentally optimal trajectory.In the ATM eYciency study of the OmegaPartnership we have been trying to quantify just howfar from that environmentally ideal case we are in thecurrent traYc management system, particularly inEurope but, also, we have been doing some otherworks comparing European eYciencies with otherparts of the world. In the submission we identifiednot only the current levels of ineYciencies, whichstand at somewhere between 10% and 15% (that is,some aircraft are flying about 10–15% further than

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the ideal case) in Europe, but also we identified someof what the causes of that ineYciency are. Omega istrying to identify what the most important causes arethat are leading to those levels of ineYciency with aview to then informing the technology developersand the stakeholder community, such as the ATMproviders, of some of the highest priorities are assupported by the data analysis we have been doing.

Q77 Chairman: The wholesale removal of largerestricted areas is one of the things you suggest.Would that not compromise safety?Dr Reynolds: One of the things we identified as beinga primary driver of excess track distance was the factthat the aircraft are flying standard routeings andstandard flight levels, which is a necessary structurethat is imposed on air traYc management systems tomaintain safety, and many of those standard airwaysare flying around restricted airspace. One potentialoption for improving the eYciency is not removingthe structure but removing some of the obstacles towhere that structure can evolve and how it is used.

Q78 Chairman: Is there not a safety issue here?Dr Reynolds: The structure is there to maintainsafety, and the restricted airspace is really justputting constraints on where the structure can go.For example, zones of military often requirerestricted airspace. Obviously they need areas totrain, et cetera, and so the airways route around thatrestricted airspace. If you were to remove some ofthat restricted airspace, you could still maintain thestructure which maintains the safety. So I would say,no, removal of restricted airspace does not changethe safety in any way.

Q79 Chairman: Dr Poll, would you like to addsomething?Professor Poll: All safety issues impinge uponemissions. What you do to ensure safety almostinvariably aVects the emissions of the aircraft. Forexample, the carrying of reserve fuel, which is thereto take account of unexpected events. More oftenthan not that fuel is not burned, but it is carried andtherefore there is an emissions penalty. The samegoes for the route and tracking.

Q80 Chairman: Do you agree with the evidence fromthe Manchester Airports Group that more directrouteing could be implemented widely without anynew technology or investment?Professor Poll: That is a good question: Could there-routeing be improved without new technology? Isuspect that the answer to that is no, because thesystems that are used at the moment are, let us say,tried and true: they have been around for a longtime, they are people intensive, and they are there tomake sure that accidents or incidents do not happen.Without the availability of a better knowledge of theposition of aircraft, a better knowledge of theanticipated arrival time at particular destinations, Ido not see how you could improve the situationwithout potentially compromising safety. I think youneed new technology.

Q81 Chairman: What about the removal ofstacking—do you have some ideas on that?Professor Poll: Stacking is an indication of waste inthe system. As was said before, if the aeroplane takesoV and you know its time of arrival at destination, itshould get there just when it is expected, and when itgets there the runway should be clear and it shouldcome straight into land. Any need to stack isfundamentally an expression of waste, so in an idealsystem it would not be there.

Q82 Chairman: In your written evidence you discussa number of research topics. Which are the mostimportant in delivering results in the near future?Dr Reynolds: There are a number of other Omegastudies that are pertinent to the discussion in whichthis Committee is certainly interested. The eYciencywork to which I alluded at the start is one. We havea stakeholder workshop next week which involvesgroups from overseas as well. That will hopefullyencourage debate amongst the stakeholdercommunity, but there are many other Omega studiesthat are certainly relevant.Mr Gardner: Certainly there are. They are, bynature, longer term in terms of understanding thesignificance of some of the climate science that mighthave a bearing upon where aircraft fly in order tominimise environmental impacts. That is a questionof understanding whether, for instance, one wouldspecifically wish to avoid contrail formation becauseof the environmental gains that might be achievedfrom doing that which could feed through into theATM system. Similarly, we are looking at the longerterm environmental implications of varioustechnologies in order to try to understand what thatmight mean in terms of technology or operationalstrategies which might be deployed by diVerentbranches of air transport or the manufacturingsector—that, along with some activities related tothe nearer airport environmental impact.

Q83 Chairman: Are you able to give us any idea oftime on this? In how many years can somethingspecific be produced from you that is going to makea significant diVerence?Mr Gardner: In terms of the answers to the scientificquestions, the general understanding is that we arestill five to 10 years away from bottoming out the bigscience questions that are going to enable clearerstrategising. That said, however, a number of thestudies which will be reporting over the next two orthree months will still give some pointers on that.They will give some road maps about wheninformation might be available from diVerent partsof the academic community and from industry thatwould help to sharpen up the view forward, but it isan iterative process and there are some things whichcan be done through nearer term findings and otherswhich are clearly much longer term.

Q84 Graham Stringer: Can I take it from that thatthe science of the impact of contrails on climatechange is not established? It is claimed, is it not, thatthere is a multiplier eVect from contrails? As far as I

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am aware, there is only one study that has shownthat. Do you consider the science to be establishedor is it still to be confirmed?Mr Gardner: It is still open. There have been a rangeof pieces of research, going back to the 1999 specialreport by the IPCC (Aviation and the GlobalAtmosphere) which gave the greatest uncertainty inrelation to aviation science on the contrails andinduced cirrus impacts. That uncertainty isnarrowing, but it is still fairly significant, andtherefore there will be a period of time before thatquestion can be answered. Whether it ends up bybeing a positive or negative signal is still a questionof debate.Professor Poll: This is one of the areas on which I amworking in Omega. The generation of a contrail issomething which is entirely under our control: weknow under what circumstances they are formed andwe know what to do to stop them forming. In asense, it is part of the air traYc managementproblem, because if you fly through air that is supersaturated with respect to ice then you form acontrail. If you avoid that air—which is relativelyeasy—you do not. In the climate implications ofcontrails, the one thing that is beyond dispute is thatanything you can see is not good news for theenvironment. And you can certainly see contrailsand the cirrus cloud that they tend to generate. Theother thing that you might find interesting is that thereason that aircraft fly in the altitude zones thatgenerate contrails is down to the design of theairport, because it is related to the requirement toland the aeroplane safely within a given distance.This has a first order impact on the size of theaircraft; the size of the aircraft decides where it flies.Chairman: A division has been called. I suspend theCommittee. Ten minutes if it is one vote. We will getback as soon as we can, gentlemen, if you wouldwait.

The Committee suspended from 5.00 pm to 5.28 pmfor a division in the House.

Q85 Chairman: I am sorry to keep you all waiting.You make reference to excessive mileage being flownto avoid going into expensive airspace areas. Whatevidence is there of that?Dr Reynolds: What prompted one of the Omegastudies was that there was a report from the BBC ayear or two ago that there was some evidence that onsome routes in Europe airlines were potentiallyflying longer distances and therefore burning morefuel and hence emitting more carbon dioxide inorder to fly into the less expensive airspace. Notethat every region in Europe has its own chargingrate, they will use a constant formula, but then thecharging rate in that formula is diVerent for diVerentcountries. On the back of that anecdotal evidence,Omega undertook a more detailed study to try toidentify whether this was a real issue or not on awider scale in European airspace and we examinedapproximately 100 diVerent routes between 12diVerent city pairs covering the entire extent ofEurope. We found that in the case that was identifiedby the BBC, which was some routes from the UK to

the Canary Islands they had the option of flying intooceanic airspace which is significantly cheaper thanthe domestic European airspace. Depending on thecost of fuel at that time, that was one of the onlyroutes in Europe where there was any question as towhether it made sense from a total cost perspective.The conclusion of the Omega study, therefore, is thatfrom the analysis we have done it looks like it is verymuch the exception rather than the rule that diVerentcharging in diVerent parts of Europe has any eVecton the actual route that the airlines are flying.

Q86 Chairman: Have you done any work on aircraftnoise in tranquil areas?Mr Gardner: No.Dr Self: No.

Q87 Chairman: What problems are there thatprevent the wider use of the continuous descentapproach?Dr Reynolds: Continuous descent approaches meandiVerent things to diVerent people and they aredefined diVerently in diVerent parts of the world.The perfect CDA, if you will, is when the CDA, aswas described by the CAA gentlemen, is conductedfrom the cruise altitude all the way down to theground, where in theory the aircraft should be atflight idle (that is, the engines are powered to arelatively low thrust level and hence their fuel burn issignificantly lower) all throughout the descent. Theproblem that that introduces to the air traYcmanagement task is that it requires significant co-ordination between many diVerent air traYcmanagement regions and it makes the predictabilityof the descent that much less certain and thereforeCDAs in that ideal sense are relatively diYcult to co-ordinate in the current air traYc control system.Some of the advanced technologies that are beingdeveloped, again, for example, by the SESARprogramme should enable that co-ordination tooccur much more readily and therefore enables thefull environmental benefits of CDA to be achievedmuch more fully in the future.Chairman: Thank you.

Q88 Ms Smith: I want to ask about the range of youractivities really. The comments made earlier, forinstance, about the carrying of reserve fuel on aplane and how that increases emissions, I foundinteresting. It is my understanding that there is a lotof work ongoing to produce lighter and strongermaterials for use in aircraft production, particularlyaround the Advanced Manufacturing Park, thepartnership with Boeing at SheYeld. I wonderedhow much the partnership is involved in that kind ofwork, because to my mind that could be potentiallyvery useful in reducing emissions.Professor Poll: We are trying to get a feel for what ispossible and, rather than working with thetechnologies themselves, to take a higher level viewand say, “Okay, what will that technology deliver ifit is brought through to the largest possible extent?”You talk about composite materials and, yes, inprinciple, composite materials could lead to lighterstructures—and I am choosing my words carefully

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here because simply changing the material does notnecessarily mean that you get a weight savingstraight away—but let us be optimistic: carbon fibrecomposite for use on wing structure and fuselagestructure, as on the Boeing 787, potentially, afterseveral design iterations and probably 10/15 years,you could get 25% weight reduction on thosecomponents but that does not mean that the fuelburn goes down by 25%. Fuel burn will go downmore like 10–15% and it will depend on the rangethat the aircraft is flying. There is always anattenuation between the technology and the fuelburn performance. That attenuation can be quitelarge, unfortunately.Mr Gardner: As with much of our work this issue isgeared to understanding the environmental issuesassociated with various options for futuredevelopment of either technologies, operations, nearairport impacts and the like, such that we can helpto provide underpinning knowledge to the industryor to airlines or to airports that allows them to dowhat they do better and quicker. We are not reallylooking at the details of composite technologies, weare looking, for instance in that area, at the extent towhich those might be integrated and what theenvironmental benefits might be associated withvarious diVerent scenarios and options.

Q89 Ms Smith: Overall, I take it from what you haveboth said, with all the caveats in place that werementioned, that it is still potentially a usefulcontribution towards the future of the industry.Professor Poll: From what we see, aviation can beimproved considerably if the circumstances,particularly the economic circumstances and theregulatory environment, are right. There is quite abit more that can be extracted, even without the useof high technology.

Q90 Chairman: Could you tell us if Precision AreaNavigation can help to increase airspace?Dr Reynolds: I suspect that some of the otherspeakers who are in the air traYc management fieldwould also be able to answer that, perhaps betterthan I could. But Precision Area Navigation (P-RNAV) is really a way of making trajectories,particularly arrival and departure trajectories, intoand from airports more predictable, so that they canbe programmed into the aircraft computer system,for example. One example is that some P-RNAVapproaches into any airport would be defined by aset of way points which give fixed locations on theground and at those way points you could havealtitude and speed targets that the aircraft should tryto meet. That enables the procedures to be designedspecifically to accommodate some of these bestpractice techniques such as continuous descentapproaches—and there are some others, such as lowpower/low drag approaches. They can be designedinto the procedure and, as long as the aircraft has thetechnology on board to enable those procedures tobe programmed in, the aircraft is capable of flyingthose predefined procedures very accurately. Thatenables the full environmental benefit of thoseprocedures to be obtained while also increasing the

predictability of the approaches and departures tohelp the air traYc management process get themaximum throughput as well of the resources thatthey have available.

Q91 Mr Hollobone: Could I come back to the eVectsof noise on tranquil areas. You say that you do notdo any research on this but can I ask quite a longquestion on this. You describe yourselves as a one-stop shop providing impartial world-class academicexpertise on the environmental issues facingaviation. I want to put to you evidence we havereceived from Shropshire County Council whichsays that the CAA’s West End Area AirspaceChanges have resulted in a 21% overall increase inair traYc over-flight in the Shropshire Hills, area ofoutstanding natural beauty. Natural England told usthat recent airspace changes by NATS will increaseover-flying of the New Forest National Park, theNorth Wessex Downs, the Cotswolds, the Mendipsand so on. Shropshire County Council have said,“There is a paucity of available research and modelsfor the appropriate consideration of the issuesaround tranquillity and noise intrusion fromaircraft” and they have called on the Government to“commission research and detailed studies onmeasuring tranquillity and mitigating impacts ofaircraft noise on tranquillity.” Given your role as aone-stop shop, do you agree that research is urgentlyrequired in this area?Mr Gardner: Omega has been going for two yearsnow and our initial programmes were defined bywhat were determined to be the key priority areasexpressed by government and a range ofstakeholders in terms of aviation sustainabilitychallenges. Thus far, the topic of tranquil area noisehas not come forward as an area that has beenspecifically requiring research; however, that is notto say that it could not be addressed in the future.Clearly, as part of helping address the totality of thesustainability challenge, where you are trying tobalance noise interests between urban areas andtranquil areas there may be some issues to be lookedat where academia could make a contribution. But Ithink we would need to see what the questions wereand see whether in fact it was felt that there was goodwork that could be done. It has not arisen yet.

Q92 Mr Hollobone: To paraphrase what you havesaid—and please correct me if I am wrong—theGovernment has not highlighted tranquillity as anissue about which it is particularly concerned butother organisations have highlighted this and it is anarea on which you would seek to concentrate, givenappropriate government guidance.Mr Gardner: I could not necessarily sign up to yourfirst statement to say that in fact government hassaid it is not a priority area. That I do not know. AllI can say is that in the discussions we have had it hasnot cropped up as an area where particular researchis required.

Q93 Graham Stringer: Professor Poll, you made thesensible point about the balance between safety andenvironmental issues. Do you think we have reached

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any threshold whereby because people are moreconcerned about the environment the planes that areflying are less safe? I like the idea of my plane havinga lot of petrol in the tank.Professor Poll: No, I think I can be fairly certain thatthe answer to that is no.

Q94 Graham Stringer: How can you be so certain?Professor Poll: Because, as Sir Roy McNulty was atpains to point out, safety is paramount. That is thefirst and foremost consideration as far as aviationregulation is concerned. Having said that, aviation,like every other sector, has to do everything itpossibly can to reduce its impact on theenvironment, either through emissions or throughnoise or whatever. Basically, aviation has a verygood track record in cutting out wastage. Wastagehas economic implications which operators wouldlike to see removed. Traditionally there has alwaysbeen pressure to do the kinds of things which impactemissions; in other words, fuel burn reduction andwhat-have-you, but that has always come behind theneed for safety. Aviation’s safety record is fantasticby any standards and that will not be compromised.

Q95 Graham Stringer: I do not know what thefigures would be but if instead of carrying an extra 45minutes’ worth of fuel you were carrying 25 minutes’worth of fuel, you must be reducing the safetytolerances if something were to go wrong.Professor Poll: Correct.

Q96 Graham Stringer: I am still not sure how youcan be so certain. I have been in aeroplanes that havegone wrong and they have had to land at otherairports for one reason or another and I have beenvery glad to have had a lot of petrol in the tank.Professor Poll: I can tell you that the good news isthat carrying an extra 10% of reserve fuel onlyreduces the fuel burn per passenger seat mile by 1%,so carrying a bit extra has a very smallenvironmental impact.

Q97 Chairman: That is reassurance.Professor Poll: Yes. If it was the other way aroundthen you would be concerned, but it is not a badthing to carry a little extra and nobody in their rightminds would risk a situation where they ran out offuel. That is very serious.

Q98 Graham Stringer: Are take-oV speeds beingchanged because of the noise impact.Professor Poll: The take-oV speed is not changed,because the speed that you achieve determines whenthe lift equals the load.

Q99 Graham Stringer: I take that point.Professor Poll: But if you have a nice long runwayahead of you, you can take oV at less than full power,so you can use a bigger run, and if you are taking oVat less than full power then your noise footprint issmaller.

Q100 Graham Stringer: Does that have safetyimplications if you are using less than full power?Professor Poll: No. Because the safety implicationsof take oV are that if you reach the critical pointwhere the aircraft is capable of flying but has not leftthe ground, you must be able to put the brakes onand come to a stop before you reach the end of therunway. The pilot has to do a calculation to makesure that he can get oV the runway at the right time,so if he did have to abort he still has enough runwayin front of him. That is part of the flight plan. Thatis subject to law, so that is necessary.

Q101 Chairman: Could you tell us what your view ison NATS’ target to reduce CO2 emissions by 10%per flight at 2020 compared with 2006.Professor Poll: Part of the Omega study reinforcesthe view that there is 10–12% fuel burn wastage—Iwill use that term—due to the extra distances flown,the non-ideal climb profiles, and the non-ideal ascentprofiles. There is 10% to be had and it can beextracted by use of better technology.

Q102 Chairman: You are confident that can be donewithout jeopardising safety.Professor Poll: Yes—well, first of all, I am confidentthat it is there to be worked on. My colleagues mayhave a view but I think the technology is there, it isa question of implementing it in a safe way into theair traYc management system to allow that wastageto be extracted. So, yes, I think the answer is that itis possible. I would not like to say how long it wouldtake but I do not think you need any new physics oranything to get it.

Q103 Chairman: NATS say by 2020. Is it going to beachieved?Professor Poll: It sounds good to me. They are theones with the money. The technology exists to beassembled to achieve that goal.

Q104 Chairman: You think it is feasible.Professor Poll: Yes.

Q105 Chairman: You are saying the technology isthere.Professor Poll: Yes.

Q106 Chairman: And if they have put that date—Professor Poll: The wastage is there to be reduced,the technology is available to be implemented, and ifthey are confident they can do it by 2020, who are weto argue with them?Chairman: We will end on that note. Thank you verymuch, gentlemen, for coming and answering ourquestions.

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Ev 14 Transport Committee: Evidence

Witnesses: Mr Rob Marshall, President and Chief Executive OYcer, Mr Mark Green, Vice President, Policy,Guild of Air TraYc Control OYcers (GATCO), Mr Andrew du Boulay, ATM Portfolio Holder for the AirSafety Group, and Mr Rob GiVord, Executive Director, Parliamentary Advisory Council for TransportSafety, Air Safety Group & Parliamentary Advisory Council for Transport Safety, gave evidence.

Q107 Chairman: Good afternoon, gentlemen.Would you like to introduce yourselves, giving yourname and your organisation for our records, please.Mr Marshall: Good afternoon. I am Rob Marshall,President and Chief Executive of the Guild of AirTraYc Control OYcers.Mr Green: Mark Green, Vice President Policy, Guildof Air TraYc Control OYcers.Mr du Boulay: Andrew du Boulay, AviationConsultant for Mott MacDonald and I am the AirTraYc Management Portfolio Holder of the AirSafety Group.Mr GiVord: I am Robert GiVord, Executive Directorof the Parliamentary Advisory Council of TransportSafety, with which we have a relationship with theAir Safety Group.

Q108 Chairman: Could you tell us what safetyconcerns you have about the increasing complexityof air traYc control?Mr Marshall: We do not have any major concernabout safety. Our industry is a very safe industry andany changes to procedures and air traYc controlwould undergo a strict regime of safety managementbefore any change was made. Our view, I think, isthat any changes that need to be made or are desiredto be made need first of all to go under a strict regimeof safety management. That is what we are assuredwill happen and we have no reason to doubt that.

Q109 Chairman: Does anybody have a diVerent viewon that?Mr du Boulay: As I have highlighted in mymemorandum, our chief concern is the increasingcomplexity of the air traYc controller task and howthey are going to cope in an increasingly systemisedworld where they are relying more and more oncomputers. That would be our main concern, Iwould say.

Q110 Chairman: Is that a big concern?Mr du Boulay: It is a concern, because as thecontroller relies more and more on technology, if thetechnology fails then the controller has to revert to amanual mode of operation and that is going to bemore and more problematic as they become moreand more reliant on the system.

Q111 Chairman: What about the interface betweencivil and military air traYc management? Are thereany issues there?Mr Green: I think with the civil/military co-ordination we have a very good way in which we co-operate between civil and military at the moment.There are well-worked out practices and procedures.For instance, military aircraft can already share civilairspace. They come through assigned corridorsthrough the civil routes known as crossing corridors.In addition, in some instances we have an integratedoperations room, where we have civil and militarycontrollers working in the same ops room. It isintroducing better ways of working between civil

and military. We have good working principleswhere we share airspace, so flexible use of airspacemeans we have improved flexibility and capacity asfar as air space management is concerned.

Q112 Chairman: What about the safety ofcommercial traYc using uncontrolled airspace?Mr du Boulay: I think that is a major concernbecause 70% of airproxes occur in uncontrolledairspace, so I think it has to be a priority for theCAA, for pilots, for NATS and for everybodyconcerned to address.

Q113 Graham Stringer: You said 70%. Is it on alevel?Mr du Boulay: A level.

Q114 Graham Stringer: So it is not increasing.Mr du Boulay: No.

Q115 Graham Stringer: But the number ofcommercial aeroplanes flying in uncontrolled spaceis increasing.Mr du Boulay: I would imagine so, yes, but theproportion of airproxes that are in uncontrolled airspaces has been roughly level at 70%.Mr Marshall: Our view about the provision of safetyto flights outside controlled airspace is that thesafety should be assessed and if there is a risk therethat risk has to be managed. Our view is that if therisk is high enough, that risk should be managed bythe provision of controlled airspace. In the event ofan increasing amount of activity in any area, ourdesire would be to see controlled airspacesestablished to meet that demand. We do recognise,however, the other constraints on the provision ofcontrolled airspace—other airspace users, forexample—and that would be taken into accountduring the process of the CAA determining whetheror not the provision of controlled airspace waswarranted in that event.

Q116 Chairman: Is additional airspace needed forgeneral aviation aircraft?Mr Green: At the moment, with some of the airspacedevelopments that are underway we are lookingwhere possible to return airspace to the general user.There is always a conflict of interest for the amountof finite airspace that is available. With the currentairspace developments we are trying to reverse thetrend of taking airspace and, where possible, returnairspace to the general aviation user, but, inevitably,with increased air traYc movements and increasingcommercial air transport, there is going to be apressure brought to bear on aviation users ingeneral, highlighted by certain conflict pointsbetween areas of controlled airspace, predominantlyin the South East of England, for instance betweenStansted and Luton.

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Q117 Chairman: Is there any better way of dealingwith those problems, these very big conflicts on theuse of diVerent types of aircraft?Mr Green: I think that conflict will always exist interms of people wanting to use the same piece ofairspace. The current policy that is in place, thecurrent procedures that we go through as far as theairspace change process is concerned, is in place totry to ensure a fair and equitable use of airspace byall users.Mr GiVord: Perhaps I could comment on both thosequestions, Chairman. Is there need for more airspacefor general aviation? I suspect general aviationwould answer: “Yes, please.” It is, however, the casethat many of the incidents, certainly thoseinvestigated by the Air Accident InvestigationBranch, involve general aviation rather thananything else, so there is a need to ensure that in anydebate about reallocation of airspace the GeneralAviation Safety Council is involved to get sensiblemessages across to its members to ensure that safetyis not further compromised by their activities.

Q118 Chairman: PACTS in its evidence says that theidea of an Airspace Master Plan is a good idea butnot feasible. Why do you think they say that?Mr du Boulay: In the way that airspace is plannedtoday, NATS actually does quite a sophisticated job.Airspace demand and capacity projections are madeout to 15 years and potential bottlenecks areidentified through that process of matching what thelikely demand is against what is there in terms ofcapacity. Detailed airspace planning takes place,when that change needs to happen, within about fiveyears of it happening, so it allows time forconsultation and everything else to make sure thatthe airspace change is in place prior to its need. Intrying to do anything in detail out to 2030, the life ofthe White Paper, to me would be a nugatory eVortbecause you are never going to know exactly whichairports are going to get new runways, where theairlines are going to want to place their aircraft, tothat detail out to 2030. Trying to design airspace outto that timeframe seems a waste of time.

Q119 Mr Hollobone: In terms of avoiding air traYccollisions, given your expertise, if you had to list one,two, three, the main risk factors that could lead to anair traYc collision what would they be?Mr Green: We have the risk of level passes, so whereaircraft do not adhere to their assigned flight level.We have the incursion into controlled airspace bygeneral aviation. The third one is runwayinfringements, where aircraft enter a runway whenthere is conflicting traYc on the runway. If you areasking for my top three, those would be my top threesafety concerns at the moment in the air traYcmanagement system.Mr du Boulay: You said airspace—Mr Green: Airspace infringements is my second.Mr du Boulay: Yes, so I would add that my otherconcern is general incident reporting across Europe.Whereas the UK have a very good history ofreporting incidents, not all European countries areup to that standard and there is not a level playing

field in terms of reporting of incidents acrossEurope. In the UK we look at our safety record andsay, “Yes, we think we are the best,” but until wecompare ourselves with other countries we do notknow. To take civil/military incidents, for example,at the moment about 25% of airproxes are civil/military incidents. Is that good or bad? I do notknow. The good thing is that we have the data hereand what we need to do is to analyse that data andtry, through the European mechanism, to get theother countries to sign up to incident reporting at thesame level as we do.

Q120 Mr Hollobone: Has that issue been pursued? Ifso, by whom and what is the mechanism to get theother European countries up to the UK standard?Mr du Boulay: It is part of European regulations toreport incidents. Enforcing that and getting that inplace is proving problematic. In some countries ifyou report an incident the controller becomes liablefor any mistake that he has made, so it is notuniformly implemented across Europe.

Q121 Mr Hollobone: Before we hear from MrMarshall, because we are laypeople could you saywhat you mean by “airspace infringements”?Mr du Boulay: I am talking about where aircraft aremeant to be staying within uncontrolled airspaceinfringe inadvertently into controlled airspace. Theycross a border in the sky without realising it and theyare conflicting with commercial aircraft.Mr Marshall: Perhaps I could follow up on twopoints, taking the latter one first: airspaceinfringements. I think the issue is that in some areasthe aircraft that are infringing that airspace are notequipped with modern equipment, so they do nothave, for example, secondary radar transponders onboard, so the air traYc controller is unaware thatthat aircraft has infringed that area. There aredevelopments in the UK system at the moment to tryto make that infringement protection more robust.There has recently been a tool that has beendeveloped and is now being used by NATS to detect,if you like, people being somewhere that they shouldnot. With regard to educating people to improvetheir safety reporting of cultures, it is true to say thatthe UK is probably one of the leading countries notonly in Europe but in the world for reportingincidents. That is something that has grown over aperiod of time and has been enhanced by supportfrom other organisations, such as an organisationcalled CHIRP which has been very proactive ingetting people to report, sometimes anonymously,but to try to grow that culture of reporting, to notapportion blame but to detect that something hashappened and have an investigation to find out thecausal factors and the contributory factors to thatoccurrence. For ourselves, we certainly supportwork throughout Europe to try to grow that culture,if you like, in other European air traYc managementassociations, and I am sure the pilots do likewise,through BALPA and other organisations that workin the same way that we do.

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Q122 Chairman: How would you like to change thedraft airspace change guidance? There have beensome comments that it seems too “woolly”.Mr Green: When I said it is too woolly, I think at themoment the concern regarding airspace change isthat the process focuses predominantly around theenvironmental guidance that is available from theDepartment of Transport. In the guidance from theDfT as far as airspace changes are concerned thecriteria are not prescriptive. It basically says youneed to take into account the environment, and youneed to take into account, if I could illustrate thepoint, noise and emissions. You are meant to avoidover-flying densely populated areas. There is nodefinition of what densely populated is, but, byavoiding the densely populated areas, whilst youavoid the noise impact on the ground you increasethe emissions because of the additional trackmileage. The guidance is there but it is very high leveland it is open to interpretation, so each and everyairspace change proposal is assessed after theproposal has been submitted. There is not clearguidance when you are designing and developing theairspace as to what environmental criteria you aremeant to be adhering to. There is some guidance butit is very high level and open to interpretation and wewould like more prescriptive guidance.

Q123 Ms Smith: The ASG have said that stacking isnecessary and that the consequent level of utilisationof runways means that “inter-arrival times arereduced to a minimum thereby eroding the safetymargin for error.” I want to explore that a little withyou and ask if you are suggesting here that currentairport operations are now unsafe because of thispractice.Mr du Boulay: I think the term “unsafe” is a verydiYcult term because it suggests that something iseither safe or unsafe. I do not think that is true in reallife. I think everything is a gradation of risk. Youhave to agree that an airspace full of aircraft stackinghas to be less safe than an airspace without theaircraft stacking. There may be safe procedures tocope with stacks but that does not mean to say thatthat airspace is more safe with a stack in it than it isnot with a stack in it. I think there are levels of safety.

Q124 Ms Smith: Why does stacking make it lesssafe?Mr du Boulay: Because you have more aircraft in asmall area near to each other. Any errors that occuryou have more chance of hitting another aircraft.

Q125 Ms Smith: Could that be scientifically gradedin terms of the level of risk that that represents?Mr du Boulay: I think you could do a riskassessment. There is very little data in the publicdomain that looks at stacks and says: What are therisks? What have been the airproxes in stacks? Whatis the situation today versus a few years ago or manyyears ago when there were not so many aircraftstacking? I have not seen the evidence one way or theother that says whether they are safe or not. Peoplesay they are safe because there is a safe procedurethat deals with them, but procedures are run by

humans, humans sometimes fail. That is my answerto that. The other thing is that, because stacks arenecessary to fully utilise the runway, what you endup doing is minimising your inter-arrival times ofaircraft landing, say, at Heathrow. There must be apoint at which that is no longer safe, but what is thatpoint? How do you work that out? Is two minutessafe? Is one and a half minutes between safe? Is it 2.3minutes? How has the criteria been developed?

Q126 Ms Smith: Are you suggesting perhaps that thecriteria for measuring that has not been developed?Mr du Boulay: I think the work has been done but Iam saying that there is not a set point where onething is safe on one side of it, so that at 1.9 minutesit is not safe and at 2.1 minutes it is safe. I do notthink that is true in reality. If somebody set a level,what is the risk either side? As the frequency ofaircraft landings increase, should that safety levelever be changed?

Q127 Ms Smith: You are looking for guidance really.Mr du Boulay: That is my view.

Q128 Ms Smith: Yes, on those grounds. In terms ofaddressing the issue of stacking, you wouldpresumably be looking at something along the linesof better planning of use of airspace, taking out thewastage in the system, and perhaps extra runways. Ido not know. Perhaps you could tell me.Mr du Boulay: Part of my reply—and the recentannouncement about Heathrow is an example whereyou could actually take action—is that the thirdrunway has been given the go-ahead but at a reducedcapacity; that is, only another 125,000 movementsare planned for the three runways. That means youhave a system with excess capacity in it, so ratherthan allowing all the runways to be filled up you cantake out the stacks, because you do not need to belanding the aircraft every minute. You now have thevery nice situation where you have excess capacityfor a time. The question is how you safeguard thatagainst the commercial pressures to use that runwayas much as possible. It is a golden opportunity, nowthat you have given the go-ahead to the thirdrunway, to say, “I am going to reserve some of thatcapacity to increase resilience of the wholeHeathrow system.”

Q129 Chairman: Mr Green, did you want to come inon this?Mr Green: Just on the issue of stacking. Stacking orairborne holding has been in place for many, manyyears, so we must not lose sight of the fact that it isa day-to-day operation that happens every hour ofthe day when Heathrow is operating. Heathrow hasmore airborne holding than the other airports,purely because of the runway scheduling aroundHeathrow. It is scheduled to 98%/99% of its capacity.As a result, you need a pool of aircraft fairly near tothe airport in order to provide throughput on to therunway. You could stop airborne holding tomorrowsimply by reducing capacity. In the future, with athird runway, I agree that we could hold back on theamount of capacity by which Heathrow is grown, in

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order to improve the resilience of the Heathrowoperation for a start but also to reduce airborneholding. There are concepts that are underdevelopment at the moment that are looking atreplacing airborne holds with alternative measure.For instance, there is something called Point Merge,which is an airspace design concept where youeliminate airborne holding through the use ofapplied Precision Area Navigation (P-RNAV)procedures. Ultimately, in the longer term, this is ourconcept where you hold the aircraft on the groundprior to departure, something called the NetworkOperations Plan, will assist in reducing airborneholding. But, for the time being, whilst Heathrow isbeing run at that level where capacity for demand isthere, then stacking is an unavoidable occurrence.

Q130 Ms Smith: In terms of potential reductions inemissions that presumably reducing stacking wouldachieve, how much of a contribution do you think itcould make? Would it be possible to measure thepotential contribution towards reducing emissionsfrom reducing stacking?Mr Green: There is an ongoing project at themoment looking at taking the level at which aircrafthold and taking them to a higher level. For everythousand feet that you increase the height theaircraft is holding, the studies show that you reducefuel burn by 2%—that is the fuel flow per hour getsreduced by 2%. Instead of holding, for instance, at7,000 feet, if you hold at 11,000 feet there is apotential 10% reduction in the fuel flow andtherefore in associated CO2 emissions.

Q131 Ms Smith: But not holding at all wouldpresumably increase the impact.Mr Green: The alternatives to holding could, forinstance, be path stretching, so that rather thanhaving aircraft flying a direct track, you had slightlyincreases track mileage by the aircraft flying afurther distance. There is a trade-oV between the

concept of an aircraft flying in circles or absorbingany delay that is needed during the en route portionof the flight, for instance by path stretching.

Q132 Mr Hollobone: Are there any major diVerencesin RAF air traYc control procedures to civilian airtraYc control procedures?Mr Marshall: The answer, basically, is yes. There isa diVerence in that, traditionally, civil air traYccontrollers have worked a sector of airspace and allthe aircraft within that sector are controlled by oneor more controllers acting in group. Traditionally,RAF air traYc control has been more of the systemwhereby an air traYc controller would look after anaeroplane or two aeroplanes or three aeroplanes,depending on the workload and the complexity ofthat operation. He would control those aeroplaneswherever they may be, and so it is not sector-based,it is more task-based for a particular aeroplane on aparticular task. However, I think now the militarysystem is moving more towards the civil system, sothat military controllers are now working blocks ofairspace rather than specific tasks. There is still adiVerence but that diVerence is getting closer.

Q133 Chairman: Do you have any specific UKexamples of significant safety issues because ofdelays in increasing airspace capacity?Mr du Boulay: I have not, no. It is a point I made inmy submission that the protracted process of doingan airspace change—similarly with an airportcapacity consultation too—means that you mustend up with a period where the existing system hasto cope with more and more planes until such timeas that change occurs. To me, you are inherentlyending up with a system that is more full of planesthan it would have been if the change had occurredand created extra capacity. To me, there is inherentlya reduction in the safety margin but I do not haveany data or statistics to back that up.Chairman: Thank you very much for answering ourquestions. I am sorry that we kept you waiting.Thank you very much.

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Ev 18 Transport Committee: Evidence

Wednesday 25 February 2009

Members present

Mrs Louise Ellman, in the Chair

Mr David Clelland Sir Peter SoulsbyMr Philip Hollobone Graham StringerMr John Leech Mr David WilshireMark Pritchard Sammy WilsonMs Angela C Smith

Witnesses: Mr Tim Johnson, Director, and Ms Laura Simpson, Policy Coordinator, Aviation EnvironmentFederation; Mr Lawrence Wragg, Chairman of Aviation Advisory Group, and Mr Michael Nidd, TechnicalAdviser to Aviation Advisory Group, Campaign to Protect Rural England; Mr Colin Stanbury, AviationAdviser, and Councillor Serge Lourie, Leader, London Borough of Richmond upon Thames, 2M Group,gave evidence.

Q134 Chairman: Good afternoon. Welcome to ourCommittee. Could I ask our witnesses to identifythemselves, please, for our records?Mr Johnson: Tim Johnson. I am director of theAviation Environment Federation.Ms Simpson: I am Laura Simpson. I am policycoordinator for the Aviation EnvironmentFederation.Mr Wragg: Lawrence Wragg, chairman of theAviation Advisory Group of the Campaign toProtect Rural England.Mr Nidd: Michael Nidd. I am a technical adviser tothe Campaign to Protect Rural England’s AviationAdvisory Group on aviation matters.Mr Stanbury: I am Colin Stanbury. I am technicaladviser to the 2M Group of local authorities onaviation matters.Councillor Lourie: I am Serge Lourie. I am the leaderof the London Borough of Richmond upon Thames,speaking on behalf of 2M.

Q135 Chairman: Thank you. I would like to ask the2M Group a question to start with. You suggestgiving ultimate responsibility for airspace changedecisions to the Secretary of State rather than to theCAA. How would this improve the quality ofdecision making?Councillor Lourie: At the moment the process is very,very closed indeed. We think there is a lack ofdemocratic accountability for airspace changedecisions. Certainly the last consultation was a goodexample. Airspace changes are very significant inthat they aVect millions of people. Decisions of thismagnitude should really be subject to parliamentaryscrutiny. The only way of doing that is to ensure that,rather than the director of airspace policy makingthose decisions in private, they should be made bythe Secretary of State. What we want to do is to bringthe whole thing out into the open.

Q136 Chairman: How could NATS improve itsconsultation process?Councillor Lourie: We have been through the recentconsultation and we found that it was really veryunsatisfactory. Colin is the expert so he may want toadd to this, but the documentation was far toocomplicated for a lay person to understand. Indeed,

it was far too complicated for a lot of local authorityso-called experts to understand. NATS refuse toattend public meetings, although they did come to apublic meeting when we asked them to come to theLondon Borough of Richmond upon Thames. Theconsultation did not apply even the CAA guidelines.There were no alternatives given. For example, thepossibility of stacking aircraft beyond the coast.Finally, the CAA guidance itself is out of date, usingold research. Having been through it, the fact that itis going to be repeated suggests that that is right.Mr Stanbury: They are the main points. The onlyother point that I could amplify on that is that NATSused local authorities around particularly Heathrowfor the last airspace consultation almost as a clearinghouse for undertaking the consultation process.There were huge amounts of documentationdelivered to local authorities with an expectationthat it would be distributed to local libraries andpoints of information. The problem with that ofcourse is that the local authority oYcers themselveswere often not suYciently expert in the matter tounderstand what was going on. The real diYcultywas when NATS were either not equipped to or wereunwilling to attend public meetings to come and facethe people that were going to be aVected by thesechanges, to be on hand to explain the technicalissues. That was the really diYcult point about thelast consultation.

Q137 Mr Wilshire: On this issue of how complicatedis the process, I notice that when pressure groups aretrying to frustrate the improvements to an airportthey will regularly say that they have not been givenenough information. Now we have the same sort ofpressure group coming along and saying, “We aregiven too much information.” Which way do youwant it?Councillor Lourie: As a local authority leader—I seethere are one or two former leaders here—it is verydiYcult getting the balance right. You do need toprovide full information. There are mechanisms forgetting full information. It needs to be helpful, easilydigestible information. It is a complicated area. I donot dispute that, but I think the NATS consultationthat we went through could have been simplified andexplained better. Most importantly—this is the point

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about democratic accountability—we feel it is veryimportant that the people who know, in this case theNATS oYcials, should put themselves above theparapet and go to public meetings. We have anumber of groups in our areas that are real expertsin this subject and it is important that they canquestion properly.

Q138 Mr Wilshire: I would not quarrel with you onthe question of attending public meetings. I thinkthat is but a single issue out of all of this. As a formercouncil leader, I know the frustrations you refer to.I have been there and got the t-shirt for that. Thiswhole issue of, “It is complicated. We must somehowreduce it to a level that, dare I say it, council leaders,MPs or Secretaries of State understand” is capableof compromising all sorts of things, not least safetyand security. The very fact that it is complicated andhas to be in that form of huge amounts of detailed,technical, expert information is probably thestrongest argument I know for not letting politiciansanywhere near it, because the analysis we will usewill be based upon the way politicians think, whichis to humour the electorate, I suspect, rather than toensure the whole thing is safe and secure andproducing maximum eYciency. Have you not justargued therefore that it is so technical that technicalexperts are the sensible people who should beallowed to take the ultimate decisions?Councillor Lourie: Absolutely not. I would entirelyrefute that. One of the problems about experts is theydo get very expert and techy and talk in techy terms.These are decisions that aVect millions of people. Myview of the consultation that was undertaken byNATS is that it could have been moreunderstandable. More time and resource could havebeen spent in explaining to eminent people like ColinStanbury and others, who are techy people. It couldhave been done much more simply and explainedmuch better and it was not. It was unfortunate. Thepoint I made about decisions being taken by theSecretary of State, which was your original question,is a very important one. I do not think it isappropriate that decisions that aVect millions andmillions of people should be taken behind closeddoors by experts.

Q139 Chairman: The Aviation EnvironmentFederation have put forward a proposal foraccepted thresholds for environmental impactswhich, if exceeded, would invalidate airspace changeproposals. Who do you think produce thoseaccepted thresholds and how would that work?Mr Johnson: Without a doubt I think that is a rolefor the Department for Transport in taking advicefrom relevant other government departments,including DEC, Defra and the Environment Agency,on their areas of expertise. In a way, it follows onvery nicely from the point about the Secretary ofState having control. You need someone who isdemocratically elected. What is wrong with thecurrent process is that you have perhaps out of dateand limited guidance from the department to theCAA on the environmental impacts that need to be

taken into account when NATS submits airspacechanges. The question we ask is whether they haverelevance to today’s debate. We come up with theanswer that they need to be expanded quitedramatically. It is probably not appropriate for theCAA or NATS to define those limitations or thoseenvironmental targets themselves. They have to bederived at a central government level and that iswhat we would like to see.

Q140 Chairman: Is the UK’s guidance on noise verydiVerent from current practice elsewhere in Europeor in the States?Mr Nidd: It is our own. It is being brought into linewith European practice as a result of the EuropeanNoise Directive which I think was 2002/49. Thattalks a lot about mapping environmental noise inrespect of airports which have more than 50,000 airtransport movements a year and agglomerations,which is a lovely European word. I think they meanconurbations initially above 500,000 householdsand in 2012 down to 100,000. The diVerence betweenour current practice and the practice that will berequired as a result of the European Noise Directiveis that all noise is mapped and characterised. Thenoise which arises in the evening is measured,characterised and increased by a weighting factor of,I think, four to allow for the slightly increasedannoyance propensity. The night noise input has aneven larger factor added to it of 10 to indicate theeven worse potential for sleep disturbance and thehealth consequences that has. Here, there is norequirement across all UK airports to measure nightnoise at all. Some do. Heathrow certainly does, butnot all airports are yet required to measure the noisedisturbance contours for night. They take a 16 hourday. That is what the book says and that is whatthey do.

Q141 Graham Stringer: Which airports do not?Mr Nidd: London City certainly does not.

Q142 Graham Stringer: These are airports that havenight flights, are they?Mr Nidd: Yes. Sorry; City does not. City has acurfew at night.

Q143 Graham Stringer: Which airports have nightflights where the noise is not monitored?Mr Nidd: Most of the provincial airports. The bigthree in London—Heathrow, Gatwick andStansted—do. My own friendly, local airport doesbut it does so on a voluntary basis.

Q144 Graham Stringer: It is doing it?Mr Nidd: It is doing it but nobody, apart from the bigthree I believe, is required—

Q145 Graham Stringer: I am not interested in therequirement. You made a statement that said someairports do not monitor noise apart from 16 hours aday and those airports have night flights in the othereight hours of the day. I just wanted to know whichthey are.

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Mr Nidd: If it will help the Committee, we cancertainly send you in some written evidence aboutthat.

Q146 Graham Stringer: That would be helpful. Canyou tell us about your tranquillity maps?Mr Nidd: Yes, a little. That particular area is in mygeneral knowledge rather than in my specificknowledge. I can tell you how they were derived,which may help. Tranquillity to CPRE does not justmean quietness. We are talking about all the othercontributions to what the public perceive as being atranquil scene. We are talking about landscapecharacter, intrusions into it, manmade largely, ofwhich noise is one. The work was done for us largelythrough some experts in the University ofNorthumbria, who interviewed literally tens ofthousands of people. I suppose to an extent theymight have been self-selected people because most ofthe interviews were done in places where you wouldexpect to find tranquillity, Areas of OutstandingNatural Beauty, local view spots and so on. Theywere asked the simple questions: do you think this isa tranquil spot? How could it be made moretranquil? What would be happening to make it lesstranquil? We got a whole range of answers fromthose ice cream vans over there. “Why is the placesurrounded by car parks?” and, “It would be nice iffewer people were here.” Out of that, this spot-by-spot-by-spot over the country, this mapping exercise,was done.

Q147 Graham Stringer: That sounds to me like aprocess that allows CPRE or anybody elseproducing a tranquillity map just to say, “This is anarea we don’t want any noise in”, so it sounds verysubjective to me. In your list, you did not list anyreally objective criteria like decibels or frequency.Mr Nidd: I think there is quite a good reason for thatbecause what we are talking about is what is theperception of the general public, not a specialist setof perceptions.

Q148 Graham Stringer: So it is subjective?Mr Nidd: Of course.

Q149 Graham Stringer: Just let me give you a bit ofbackground. I have been involved in two or threedebates on the floor of the House of Commonsaround discussing noise in Nottinghamshire andLeicestershire associated with East MidlandsAirport and what the Members of Parliament say is,“Yes, there is less noise here than over Nottinghamor Leicester, or Manchester for that matter, but thisis a rural area and you notice every aircraft”. Thatjust seems to me to say that you should never fly anaeroplane over the countryside and that it is asubjective measure.Mr Nidd: I think there are some objective measuresthough relating to the ANASE Study and the waythat the 57 decibel contours, it is not a contour,

whatever the line is, and Colin is much better atexplaining it, but it just seems to me that there is alot of evidence that people no longer will accept astranquillity what was accepted as tranquillitypreviously. Colin, do you want to add to that intechnical terms?Mr Stanbury: You did ask was our noisemeasurement the same in Europe and, if you wouldlike some more detail on that, I will try and assist theCommittee. The answer to that is that, in a way, it isevolving. Our system of noise assessment is not thesame as in Europe and Europe is tending to do itsown research, of which of course we take notice andare aware, but we are very much still steeped, I fear,in policy which relies on social surveys andassessments that were done getting on for 30 yearsago. This is one of the points that my colleagues herewere making, that the benchmark, if you like, of theCAA’s guidance in terms of when airspace changesmay be significant or not is actually rooted in theresults of social survey work that, as I say, goes backover 30 years, and perhaps one of the mostunfortunate things that has happened in recent timesis that a very far-reaching study that wascommissioned, the ANASE Study, which mycolleague on my left here referred to, was publishedand the Department for Transport are unhappy,seemingly, with the way that that study wasundertaken.

Q150 Chairman: It had a very bad peer review.Mr Stanbury: And the peer review, that is absolutelythe case, was not entirely favourable, but what itdoes appear is that there are parts of that study thatcan be in fact relied upon, and what the 2M Groupis actually saying, and I am sure my colleagues herewill share this view, is that those parts of the studythat are considered to be in tact and robust should bereconsidered by the Civil Aviation Authority and theDepartment for Transport in setting forwardstandards for the future in terms of, if you like,response to noise, particularly aviation noise,because it is very much a step forward in terms of thecurrent perceptions of people and their reactions toaviation noise.Chairman: But it did get a bad peer review.

Q151 Mr Leech: First of all, can I, just for safety’ssake, declare a non-pecuniary beneficial interest in apiece of land at Heathrow, just to be safe.Mr Lourie: Perhaps I should have done the same!

Q152 Mr Leech: I would like to talk about the CAAdecisions and the appeals process. The 2M Grouphave said that the judicial review process is limited inscope. What do you mean by that exactly?Mr Lourie: I think that what we are saying is that, ifthe decisions which are currently taken by theDirector of Airspace Policy at NATS were takenmore openly, at the moment to challenge a decisionby the Director of Airspace Policy requires us to go

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to court and have a judicial review and that isactually quite a diYcult process and courts get quiteconfused. Mr Wilshire made the point about thecomplexity and even courts get quite confused aboutthese things and, at the moment, the JR is very mucha theoretical tool for us. In other realms, likeplanning or whatever, there is an appeal mechanismand there are ways in which you can challengedecisions.

Q153 Mr Leech: Can you make any specificproposals for how you would like to see changesintroduced?Mr Lourie: Well, we have. In the email that was sentto you by my colleague, Eddie Lister, the Leader ofWandsworth Council, he did make some suggestionson the lack of democratic accountability, and it wasa point that was raised earlier, Chair, by yourquestioning about who was the appropriate personto make the decision, whether it should be made insome democratic form, and I know Mr Wilshire didnot agree with that, but I do think there should besome parliamentary scrutiny of decision-makingand, as far as I can see, and you may know betterthan me, the best way of doing it is to get theMinister to make the decisions.

Q154 Mr Leech: Have these representations beenmade to the Department though and to ministersand, if so, what sort of response have you hadfrom them?Mr Lourie: We have made the representations toyour Committee and we thought that that was theappropriate way of doing it. We have not madeimmediate representations. We find that theDepartment is quite diYcult to deal with, I have totell you. They always seem to be, and this is a pointwhich was raised in the very good documentproduced by the House of Commons Library, thatthere is a lot of, I would not use the word“collusion”, that is the wrong word, but there is a lotof to-ing and fro-ing between the Department, BAAand others and it does look to me as if there shouldbe some independent scrutiny of the decision-making. Certainly, at NATS we would like to seesome external control preferably, I think, throughyour Committee or through Parliament.

Q155 Mr Leech: The Chiltern Countryside Groupsuggested possibly introducing an ombudsman.Would you support that or would any other panelmembers support the introduction of anombudsman?Mr Lourie: I will not give you a quick answer,superficially it sounds attractive, but we would haveto think about it. What we would like to do is to havesome mechanism, and we are talking about airspacepolicy. We would like to see some transparency in thedecision-making and some ability to question thedecisions with some independent body, and it maywell be that an ombudsman would be appropriate,but I have not really thought about it until now.

Mr Johnson: There is a very good model actually inFrance, an organisation called ACNUSA that sitsbetween the Government and the aviationcommunity and provides advice to the Governmenton just these sorts of issues, so they take evidencefrom industry and from community bodies and theytake those and make their own assessments. Itcomprises largely academics and independentexperts and, although they do not have any decision-making powers, they have some powers ofenforcement and they have some mediation powersand they do actually, as I say, make representationsto the French Government on particularly largeairport expansion decisions or on airspaceexpansion decisions, and that would be somethingthat would be worth looking at.

Q156 Mr Wilshire: This really leads on to where Iwant to go, this question of ownership of airspace.CPRE suggested that the whole issue should be putin the careful hands of the Environment Agency, butthe issue that you just raised, Mr Johnson, of amediation role, I suspect even I would be on yourside on mediation on enforcement, a long way fromdecision-taking, and I think that is the key point. Wehad the issue, did we not, of one minute there is toomuch information, the next minute there is notenough information, and we have heard again from2M that “collusion” is the word they wanted to geton the record, though they say they did not reallymean it—Mr Lourie: Sorry, I did not mean it. I really did not,so I apologise.

Q157 Mr Wilshire: We have a situation there whereone minute the Department for Transport talks tothe people who own airports and that is somehowimproper and, if they do not talk to them, it issomehow stupid that they have not consulted thepeople who own airports and know more aboutthem than anybody else probably, so we keepcoming back to that. We now get to a situation withthe ownership of airspace where the CPRE is sayingthat it should be taken away from the experts andhanded to the Department for the Environment.Could the CPRE tell us what decisions would bediVerent? What would be decided diVerently andwhat diVerence would this make in the future?Mr Wragg: In terms of technical decisions, thedecisions will be made the same way and will havethe same output. The issue that we see is thatairspace, at the moment, is treated almost as aprivate good for the benefit of a limited number ofcommercial interests, and we think that that is amistake and, when we argue that it should be ownedfor the benefit of the community as a whole or thatthe Department for the Environment might be asuitable home for it, it is simply to bring a widerperspective on the use of airspace so that it does notfall into the hands of people that you might regardas experts who simultaneously have a commercialinterest.

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Q158 Mr Wilshire: You say that it is for the benefitof a limited number of people, but is it not the casethat the people who benefit from the best use ofairspace are the travelling public who want to do itas safely as possible, as conveniently as possible andas cheaply as possible? Are they not the people,ultimately, who matter?Mr Wragg: The answer to the first part of yourquestion is yes, the travelling public does indeedbenefit from it, but it imposes costs on the rest of thecommunity which are frequently overlooked or, ifthey are not overlooked, they are not given theappropriate value. That is the reason.

Q159 Mr Wilshire: If you were to have your wishgranted and the Environment Agency took this over,how would you be able to persuade me that theEnvironment Agency would not compromise safety?Where would they get the expertise from to make thefinal decision on any safety argument?Mr Wragg: I believe that the expertise on safety isthere.

Q160 Mr Wilshire: In the Environment Agency?Mr Wragg: No, in the existing organisations, such asthe CAA and NATS.

Q161 Mr Wilshire: But they, at the moment, have theright to say yes or no and you would be taking thataway from them.Mr Wragg: They would be given a better overalldirective as to the environmental consequences ofwhat is being done than they have now, and this hasalready been alluded to. At no stage do we or, Isuspect, anybody sitting here suggest that anythingshould happen which would compromise safety.

Q162 Mr Wilshire: But handing the decision-takingover to the Environment Agency and taking it awayfrom the CAA, would that not in itself put it in thehands of non-safety experts?Mr Wragg: It was to make sure that things likegetting alternative proposals put forward to beconsidered at the same time would happen when ithas not happened as it should have done recently.

Q163 Mr Wilshire: Who would decide which is thesafest alternative if several alternatives were putforward—the Environment Agency?Mr Wragg: I do not want to speculate, but I wouldhope that nobody from NATS or the CAA wouldput forward a proposal that was unsafe.

Q164 Chairman: But it is a question of who is goingto make a decision and who is going to assess that,and the question Mr Wilshire is putting to you is whyyou think the Environment Agency is fit to be ableto do that.Mr Wragg: The Environment Agency would not bedeciding on safety issues because it has the CAAthere to do it, to provide it with the expertinformation and, therefore, judgment. The question

is simply that, at the moment, the motivation forproposals can be 100% commercial for people whoare providing the travelling public with aeroplaneservices, and we are saying that there are more issuesto be taken into account than simply operationaleYciency for a limited number of airlines.

Q165 Mr Wilshire: I would find that the argumenthad a bit more credibility if it were an argumentabout the planning process because, at the moment,you hand over the decision-taking on the use ofairspace to somebody else and yet you leave thearrangements in place where people can say, “Youcan build an airport, you can build a runway”, thenalong later on comes somebody else who says, “Well,you built it, but you can’t use it because we’re notgoing to let you use that airspace”. Now, is not yourway round, and I can see what you are trying to getat, but is not this way of doing it the wrong way?Mr Wragg: We would very much like to see anintegration between the use of airspace decisions andthe planning process and we think it would be verysensible, for example, if somebody wanted to expandan existing airport, that they made sure, before theystarted putting various plans into an application,that the airspace that would be needed as aconcomitant were to be available.Mr Lourie: I wonder if I could comment on thatbecause it was an issue that we encountered in ourdealings with NATS on the consultation, which wefound very interesting. We were being consulted onthe terminal control north proposal, but, because atthe time we were in the height of the debate of thethird parallel runway at Heathrow and the sixthterminal and all that, we did ask if they could tell uswhat was going on in terms of providing the airspacerequired for the massive expansion of Heathrow thatwas being proposed, and it was quite clear from theresponse that no work had gone on. I think one ofthe issues is that the White Paper and the way theGovernment operates does encourage a piecemealexpansion of a number of airports without reference,particularly in the South East, to the amount ofairspace capacity, and it does seem to me that it isputting the cart before the horse to say, “We willexpand this airport or that airport” when there is alot of pressure in the South East without actuallylooking to see whether the airspace is availableunder present technical conditions.

Q166 Mr Wilshire: That argument is again slightlyflawed in that the Government’s policy decision onexpanding Heathrow is but a policy decision andthere is no planning application.Mr Wragg: Indeed.

Q167 Mr Wilshire: And, when the planningapplication comes to be considered by whoeverconsiders it, then airspace issues will become part ofthat planning process, so to suggest it is the cartbefore the horse just is not fair. NATS make theargument that to do the preparatory work until

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somebody comes forward with a definite proposalrather than a policy statement is not the way theywant to work, but they certainly will do, and aredoing now, the work for the planning process. Thisbrings me back to the point I was making that theEnvironment Agency really I cannot see is the bodyto safeguard some of these issues which, I accept,you are rightly concerned about, but surely it is theplanning process?Mr Lourie: My understanding, and I may be wrongand you may well be right, and I apologise if that isthe case, but my understanding, and I will turn to mycolleague on my right here, is that airspace issues arenot part of the town planning process, as weunderstand it, in local government and that that issomething entirely separate and is not considered aspart of the planning process. Certainly, in all theplanning inquiries that I have been involved with,the airspace issues have never been part of it and itdoes seem to me that it is putting the cart before thehorse, that you expand an airport and then seewhether you have got the capacity in the South Eastto do it.

Q168 Chairman: But NATS say that it will be tooexpensive to do that with every proposal.Mr Lourie: At the moment, in south-east England,as I understand it, the airspace is very limited. It isabsolutely chock-a-block, although I understandfrom colleagues that the recent reductions in airtraYc have actually made things easier, but certainlya year ago the airspace seemed to be very full.

Q169 Mr Wilshire: I have just one last question onthis point and then I will leave it alone, Chairman.Would you not accept, irrespective of what thelegislation may or may not say on town and countryplanning, that Ferrovial, for example, are not goingto part with £15 billion until they are entirelysatisfied that they can actually use the airspace forthe new runway we need.Mr Lourie: Well, clearly, but you made the pointabout safety and clearly safety is paramount, butthere are disbenefits to people on the ground andthose are issues which, at the moment, do not getconsidered in the whole issue relating to airspace,and there are people who suVer from aircraft noiseand that is actually something that needs to beconsidered.

Q170 Ms Smith: I just wanted to ask about the twodiVerent aspects of environmental impact which, Ithink, need to be put on the table, first of all, thatvery eYcient use of airspace can lead to a reducedenvironmental impact, but it can though also lead toan increased impact in terms of noise levels on localpopulations, so, in the end, is it not a balanced viewthat we have to take, that the Government has totake, in terms of which environmental impact has tobe given the greater consideration?Mr Lourie: Absolutely, and that is why we think theGovernment ought to be making the decision. I usedthe word “colluded” and then withdrew it, butactually I notice it is in the report, though I still

withdraw it, but there is an issue about how thesedecisions are made and the balance betweeneconomic benefit to the country and environmentalbenefit.

Q171 Ms Smith: I was not talking about economicand environmental, I was talking about the reducedenvironmental impact of dealing with the amount oftime that aeroplanes are circling in the air andstacking around an airport, reduced CO2 emissionswhich can result from making better use of airspacethrough having perhaps an extra runway, but thedownside of that may be increased noise levelsbecause of new flightpaths and so on.Mr Lourie: Those balances which, rightly, theGovernment should be making and Parliamentought to be monitoring.

Q172 Chairman: Mr Nidd, would you like to give ananswer on that point?Mr Nidd: Only perhaps to help Ms Smith or toinform Ms Smith that one of the things we have beenurging on our NATS colleagues for a long time isthat the way they handle the air traYc is a bit short-term and it is as though it suddenly pops up over theradar and it is there. They have just started doingsomething which we have urged them to do which isto, in eVect, take ownership of an incoming flightmiles and miles from the airport at which it isintended to arrive and to say to it, “If you carry onlike this, you’re going to arrive too soon and we willhave to stack you. Back oV a bit and then you can flystraight in”.Ms Smith: I do not think I need any help on that!

Q173 Chairman: Mr Johnson, can you add to whathas been said?Mr Johnson: It is precisely on your point about theglobal versus the local tensions and whether you canhave both. You have got diVerent constituents outthere and the community will always be interested innoise. Increasingly, the Government will beinterested in the emissions side, airlines willincreasingly be interested in the emissions side, andthe inclusion of aviation into the Emissions TradingScheme will make sure that airlines will be saying toNATS, “Design us a system that gives us the mosteYcient routes in and out”, but you have got to tryand reconcile that. I think, precisely because youhave these diVerent pressure points, that the CAAand NATS taking that value judgment about whichto prioritise over the other is inappropriate. It isexactly why we argue that you have to have“sophisticated” guidance, I suspect, is the word fromthe Department for Transport, something which isnot just narrowly defined as, “This is the answer onnoise” and does not say very much on emissions,something which actually says that, in diVerentcircumstances at diVerent times of day, there arediVerent areas and there are diVerent environmentalpressures that have been brought to bear, and itrequires the Government to interpret that, takingadvice from all of those outside bodies. Thetranquillity point, Mr Stringer, is not just something

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that the environmental organisations advocate, it ispart of the EU Directive, but unfortunately they donot define it and they do not define high noise levelsfor us either which requires the Government toactually say, “What does that mean in a UKcontext?” but there are a lot of environmental issuesthat NATS and the CAA are struggling with onwhich they have no numerical outputs to put and for

Witnesses: Mr Christian Dumas, Head of Sustainable Development and Eco-eYciency, Airbus; Mr KevinBrown, Vice President and General Manager of Air TraYc Management, The Boeing Company; and MrBruno Esposito, Director of Civil Air Transport, Society of British Aerospace Companies (SBAC), gaveevidence.

Q174 Chairman: Good afternoon, gentlemen. Sorryto have kept you waiting, but I hope you found theprevious sessions of interest. Could I ask you pleaseto identify yourselves.Mr Brown: Good afternoon. My name is KevinBrown and I am employed by The BoeingCompany where I currently serve as Vice Presidentand General Manager of Boeing’s Air TraYcManagement Initiative.Mr Esposito: Good afternoon. My name is BrunoEsposito and I am the Director of Civil AirTransport for the Society of British AerospaceCompanies.Mr Dumas: Good afternoon. My name is ChristianDumas and I am Vice President of EnvironmentalAVairs of Airbus and previously I was in the jobof Project Director for the SESAR definition phase.Mr Wilshire: Not a British subject among you!

Q175 Chairman: Well, I did not like to mentionthat!Mr Esposito: The fact is that the business isglobal now.

Q176 Chairman: We are glad that you think thatthis is suYciently important to be here with us. Inthe evidence from Boeing, you do say there is scopefor improving the operational performance ofBritain’s airspace, as there is for many countriesaround the world. Are you suggesting there that theUK’s performance is worse than other countries’,or what were you actually getting at there in thecomment you made that there is scope forimproving the operational performance of Britain’sairspace?Mr Brown: That is precisely my job for The BoeingCompany. You will notice that I called it an“initiative”, not a business. My focus is outcome-driven to try to advance the state of the art of airtraYc management and not necessarily derive profitfrom it. It is born out of our corporate belief thatthe travelling public fly because they believe it issafe and that we have an obligation to our airlineoperators and the communities to try to help makethe system as operationally eYcient and asenvironmentally progressive as possible. We believethis is a win-win-win opportunity where one canhave higher capacity and yet better environmental

which they have actually got no political guidanceon where they put those priorities and, for thatreason alone, we feel the Department for Transporthas to be more forthcoming and actually telling bothorganisations what they have to achieve whenconsidering airspace changes.Chairman: Thank you very much for coming andanswering our questions.

performance with better schedule performance andfuel burn, and we have big programmes, likeSESAR and in the US NextGen which areimportant, but we have capabilities on aeroplanestoday, like required nav performance, which havedemonstrably shown that the system can beimproved today. One example is that we, Boeing, inpartnership with the FAA and NASA and UnitedAirlines in the United States have been piloting atechnique called “tailored arrivals”, trajectory-based flight arrivals where the aeroplanes comedown at flight idle in very precise nav corridors. Wehave shown repeatedly that a 747 arriving at SanFrancisco from top of descent will burn 2,800pounds less fuel than a traditional steppedapproach with the very prescriptive approachcorridors that are used in today’s system, so we areresolute in the belief that there is opportunity todayand we are committed to supporting it.

Q177 Chairman: How do we compare with othercountries?Mr Brown: In the UK, I work very closely withNATS and I am very impressed. They are a veryprogressive air nav service provider, they are veryinterested in not only improving the operationalutilisation of the system, but improving their owninternal performance by being leaner and morecost-eVective. We have diVerent challenges. In theUS, our challenge is weather in the summertime,principally, that disrupts our system. Yourchallenge, as I view it, here in Europe is that youhave a very fragmented system with 27 air navservice providers and a very small footprint, theharmonisation of civil and military airspace, andLondon Heathrow, in particular, being an airportthat is tremendous in terms of its capacityoperating out of a footprint which, I think, is ofthe order of about 4.2 square miles, to compare thatwith the Washington Dulles Airport whosefootprint is 42 square miles. As a result, I think ourcosts per operation in the US are lower and I thinkour flow management techniques, because wemanage air traYc all the way across the Continentof the United States, puts us in a somewhat betterposition in terms of the stacking that youexperience here at London Heathrow, so it is a very

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complicated ecosystem and there are complexitieseverywhere that need to be considered, but lessonswe can learn.

Q178 Chairman: In the evidence from SBAC, theSociety of British Aerospace Companies, you seemto be cautious about the introduction of continuous-climb departures. Can you tell us more about thatand what assurances you would be looking for?Mr Esposito: I think that the whole topic aboutaviation is to be replaced not only at an airport levelin terms of arrival and departure, but also with theairspace itself that needs to be managed. In order tohave a continuous-climb or descent approach, youneed actually to have a very eYcient and lean systemwhich is, what could be considered, data network-centric where the flow of information is shared bymany stakeholders and this form of information willoptimise not only the arrival and departure, but alsothe airspace system, and that is where we are a bitcautious. We are a bit cautious on the fact that onehas to avoid decoupling, as part of a whole systemthat is needed on a global basis, one segment of thesystem because the eYciency and the optimisationthat you would get can only be there if actually allthe players are able to contribute in an eYcient way.

Q179 Mr Wilshire: I think it would be helpful if I, fora moment, played devil’s advocate and put to youthree arguments that are often levelled against notonly aircraft manufacturers, but the people whooperate them, just to explore this. There are thecynics who say that all you are really interested in isimproving your profits by making these sorts ofairspace changes, there are the nervous who say thatwhat you are really going to do when you are tryingto increase your profits is compromise safety bymaking these changes, and then there is the anti-everything brigade who say that what you are,ultimately, going to do by doing this is to increaseemissions, increase pollution, et cetera. Those are thearguments put against you. I am sure you have gotanswers to them and it would be quite helpful tohear them.Mr Dumas: Safety is paramount for aviation. Wecould not even consider wanting to do somethingthat was not safe because this would actually spoilour business. Everything in terms of a safetyproblem is bad for our business, for aviation, and wewould never do anything that would spoil safety ordiminish it in any way.

Q180 Chairman: You would not be tempted tosave costs?Mr Dumas: No. For us, safety is really the basis ofthe business. If I take, for instance, air navigationservice providers, their original mission is to ensuresafe supervision of the aircraft. This is what theyused to do for decades and decades. Now, with thegrowth of aviation, they have to provide better andmore eYcient services because they have to considerother aspects, such as making flights more eYcient,more direct and less polluting, and I would remindyou that one of the objectives of the SESARProgramme, Single European Sky Research, is to cut

emissions per flight by 10%. That being said, I agreethat, if the growth of traYc continues, the 10% on aper-flight basis, it is not global, but still we have todo this and we have to improve air traYc controlpermanently if we want to maintain sustainablegrowth of the traYc, but we will never compromisesafety.Mr Brown: If I could expand, and, Christian, thankyou, I have been with Boeing for 30 years and it isengrained in every employee’s DNA that the publicfly based on a contract of trust that the system is safe,and I am glad to see during my career, and I haveenjoyed time spent on the 777 design developmentprogramme, NextGen 37, and I have never seen adecision made that addressed a safety item where thecompany did not commit to doing the right thing.We would be spoiling ourselves to do so. With regardto improving profit, we are dotcoms, both Airbusand Boeing. I have to say to you candidly that wehave never mourned at the win of a sales campaignand we do look at aviation and, given where marketpressures want to drive it, aviation does want togrow globally, but we recognise that, in order to dothat and to be both responsible and not subject toexternal constraints, we absolutely have to partnerto address environmental and operational eYciencyissues both with our products where we competewith Airbus viciously, but also in the operation ofour products in the global air traYc managementsystem where actually Christian and I have knowneach other for seven years, are good friends,colleagues, and collaborate on an advancement ofATM solutions. We may compete as aircraftmanufacturers, but we do not believe it servesanyone in the aviation community to not see thewhole advance in terms of the more eYcient, morerepeatable, safer operation of our products in thesystem.Mr Dumas: There are three areas where Airbus andBoeing do co-operate and these are safety, air traYcmanagement and environment where we really co-operate. We signed an agreement, for instance, withthem last years in Geneva.Mr Brown: On safety, air traYc management and alittle on the environment, we think we have got someways to do it a little better.Mr Dumas: Yes, you can always do better!

Q181 Mr Wilshire: What is wrong with air traYcmanagement in the UK, which is what we arefocused on, but also in Europe, if you like? What iswrong which needs improving?Mr Esposito: Can I please go back to your initialquestion because I gave the floor on that. First of all,I think that, as a conclusion of what my twocolleagues said here, I would like myself to add thatthere is a tremendous need, in my opinion, toactually educate the public at large. Aviation is notjust going fishing, it is a way of life, it is a businessculture and I can assure you that, as a pilot, eachtime I take an aircraft, safety is the key to thesuccessful outcome of any mission, be it commercialor general aviation. The second aspect that I wantedto bring into the debate is the fact that yes, there is atrade-oV, but the industry as a whole is investing a

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great deal, millions of pounds, on an ongoing basisto actually accommodate and improve any eYciencythat one can see, and that is around the climatechange parameters that you were speaking aboutwhich are attached obviously to the eYciency ofdoing a certain type of trajectory at a certain timeand even in certain weather conditions. In essence, Ibelieve that, one, we need to educate people and,two, the industry is making a great deal ofinvestment in order to ensure that what we are doingcomplies with the existing regulations and will evengo further than the existing regulations in terms ofclimate change as we stand, and, last but not least, Ibelieve that, if one key word could be extracted aspart of the aviation sector in any compartment ofgeneral aviation, commercial or military, it has tobe “safety”.

Q182 Mr Wilshire: I will go back to the secondquestion I asked, which is what is it about air traYcmanagement in the UK and in Europe that needsdealing with, needs improving? What is the problem?Mr Esposito: I would like just to state here that,unlike in the States, as Kevin has just observed, wehave to deal with what is still a completelyfragmented approach. We have 27 nations, or moreactually, that have their own service providers, theirown way of dealing, their own procedural way, andtheir own systems. If we want to be eYcient, if wewant to optimise the route in traYc in terms of notonly capacity, but reducing CO2 emissions, I wouldlike to quote here that, if we were actually to apply,what we call, a “continued descent approach” in apositive way on all the traYc in Europe only, wewould save per year 492,000 tonnes of CO2

emissions, so, because of the fragmented approachthat we have in Europe compared to other parts ofthe world, we are not optimising the flow of traYc,and that goes also for the fact that, if were in theSESAR Programme, and we will address that intime, in planning better not only the departure andthe arrival, but the route trajectory, we will be alsoable to optimise a great deal not only the climatechange aspect, but also the traYc growth andaccommodate it.

Q183 Mr Leech: What impact would those changeshave on noise?Mr Esposito: In terms of procedure to address noiseabatement, you have several aspects to consider. Thefirst is the climbing aspect when the aircraft leave theground, and of course the problem here is that youhave the full power setting, for obvious reasons, andit is a factor of a lot of the aircraft. Traditionally,what we tend to do today is to start the climbing,then to do a step where you stop your climbing andthen to climb again and so on and so forth. If wewere to actually climb and use the energy of theaircraft in a better and leaner mode all the timeinstead of doing the step, we would reduce the noiseand we would also optimise the eYciency of theenergy and, therefore, reduce also the fuel burn. Onthe arrival side, because I am assuming that we arespeaking of close to the airport, to go back to yourquestion, you have either to consider a continued

descent approach or a steep approach or also onethat we call “low power, low drag”. The eYciency ofthis approach can only be applied and accommodatewhat we are speaking about if the fragmentation,which I spoke of before, if there were a better use ofthe diVerent airspaces that we have to work in. Togive you an example of that, because I can see agentleman that is agreeing with that, if I were, as apilot, arriving from France, I have two points ofentry and I can only start my descent from flight level250, so 25,000 feet, at a precise location when I amhanding over from the French air traYc control tothe UK air traYc control. The optimisation of whatI am speaking about is that I could actually start, stillwith the French, my descent, not touch, as a pilot,my power setting, reduce the noise, improve andoptimise my drive by putting down my landing gearand my flaps at the optimum moment and alsoreduce the fuel burn, so a great deal can be achievedif we were to have a less fragmented airspace withless players and a better and more eYcient flow ofinformation in between all the stakeholders and notjust between the air traYc controllers, but the piloton board and the airport as well on the ground.

Q184 Mr Leech: So what model would you like tosee introduced then to stop that fragmentation?Mr Esposito: Well, I would like to use the modelwhich is currently under development, which is theSESAR model. The problem I have with the SESARmodel myself is that it will take too long toaccommodate what the industry needs today.Mr Dumas: If I may go a little bit further, theproblem we have is that, if we want to reduce noiseand if we want to reduce CO2, we have to find theright trade-oV at every airport, every airspace level,et cetera, which means that, one way or the other, ifwe want to move more traYc as well, we will have tobring in much more automation to the groundsystems and to the aircraft themselves. This cannotbe done at the local level, which means that theremust be a global agreement, so Europe, but the USand more widely as well, to determine how we aregoing to introduce this automation into the groundand airborne systems. This is what we have tried,and achieved, through the SESAR Programmethrough the definition phase to bring all thestakeholders together and to say, “Okay, guys, whatdo we want to do?” and, I agree, it is a little bit late,but we say that we can do it by 2020 and, until then,we shall do some short-term fixes here and there, but,by 2020, we must have this not fully automated, buta much more automated system which will actuallyallow each airspace-user to fly the so-called“preferred user trajectory” and that will deal withnoise and that will deal with CO2.Mr Brown: I think, Mr Wilshire, you asked thequestion of what is wrong and Bruno responded, Ithink, appropriately with functional airspacereorganisation as necessary, but not suYcient, asChristian tried to draw out. Part of the problem isthat the system operates today on 1950s’ technology,radar surveillance of aeroplanes, voicecommunication between ground air traYc controland aircraft and fundamental assumptions that,

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because of that, the system really does not knowwhere those aeroplanes precisely are, so there arevery prescriptive routings and separation standards.What SESAR anticipates and what we, as acommunity, can start moving towards today isrelying on the fabulous navigational capabilities thatare on commercial transport aircraft, and we havetalked about required nav performance andcontinuous descent approaches, and migratingtowards a more information-centric system whereground automation and aircraft automation,ultimately, interact with each other. This is not goingto be a flip of a switch and, with some of the pilots Ihave alluded to that we have worked with withAirbus in Australia and with the FAA in SanFrancisco, it shows a little glimmer of what ispossible today to start us on that journey and toaddress some of the eYciency and environmentalconcerns that exist today, so it is the combination,organisational and technological; it all has to comeon.

Q185 Ms Smith: Going on from that, and I thinkthat is absolutely right, that, ultimately, would leadto a focus on arrival time rather than necessarilydeparture time in the future because the key thingwill be to have aircraft landing according to theschedule prescribed by the controllers and accordingto the information of that approach which you havejust described. Would that not put a fresh onus onthe airlines to manage much more successfully theexpectations of their passengers? At the moment, theexpectation is purely about lifting oV and it is notabout when they are coming down on the ground, sothere would be a completely diVerent mindset andculture in terms of how airlines function and howthey interact with their passengers. Is that not thecase?Mr Brown: Today’s system is very tactical. Airspaceis divided into segments, you have a controller whohandles the aeroplanes in that segment and then hehands them over to the next controller. What I amtalking about in this broadened information-centricparadigm is that you push the planning and thecontrol out farther ahead. You will hear people talkabout flow management, and flow management,ultimately, for an aircraft will be gate to gate, and wewill start driving the surprises down. If you look atLondon Heathrow, a very highly utilised airport, theaeroplanes bank into Heathrow in surges fromNorth America on the overnight flights and what Iam talking about is smoothing that out.

Q186 Ms Smith: Well, that is exactly what I amtalking about. What I am saying is that theconsequence of that is much more of an emphasis bythe airlines, surely, on smoothing the system out, butit will mean managing your relationships with yourcustomers much more successfully because, at themoment, they just expect to take oV when the airlinetells them they are going to take oV and they face theproblem at the other end.Mr Esposito: If I may say, not really. When you startan engine at a gate, you start an engine at a gatebecause you have got that part of your flight plan,

everything until the gate where you arrive. Theproblem, if I may say so, on airports, such asHeathrow, for instance, but Heathrow is not the onlyone, is that the more you operate at full capacity, ifin the process you have just a little something thatcomes to perturb your flow of traYc which is closeto saturation, this little something will have a greaterimpact, so, although I agree with the managementexpectation from an airline perspective, I also haveto say that sometimes the airline knows that the pilotwill start the engine and leave the gate on scheduleand something will happen and then you have tobasically manage a diVerent type of expectation.

Q187 Ms Smith: That will always happen, but thepoint I am making still is that, at the moment, thekey emphasis of the industry and the expectation ofthe passenger base is always the time of arrival at theairport and the time of departure and, veryfrequently, to expect delays in terms of arrival andwait in the sky, stacking, for instance, aroundHeathrow, but would the new approach that we aretalking about not shift the emphasis towards whenyou depart rather than when you arrive in terms ofpossible delays and so on?Mr Dumas: I think it would shift it everywherebecause what we want to achieve is to have thisnetwork-centric system that will basically give all thestakeholders all the data regarding each flight, whichmeans that, when an aircraft has one hour to land,we are able to slow it down a little bit or accelerate,I do not know, or make a selection. If we have 10flights queuing, why should this one land and not theother one? Because it is the first, but we can changethis by saying that this aircraft should land firstbecause it has some other priorities, commercial orwhatever, compared to others. Through thispermanent picture of data between the airport, theairspace and the airlines, we can improve the system.Just to give you an example, you say that passengersare very geared to landing on time. Well, sometimesI land earlier than expected and I am furious becauseI have to wait 10 minutes until the gate opens. Thisshould stop just by telling the airport to do betterplanning and, if you get the data, you know when theaircraft is going to land.

Q188 Chairman: So you are looking for moreintegration?Mr Dumas: More integration of network-centricexternal data.

Q189 Graham Stringer: I wonder if the problemsthat our previous witnesses were talking about andwe have been discussing would be alleviated if youmade quieter aircraft. How close to the technicallimits are you in making aircraft, both the framesand the engines, quieter?Mr Esposito: That is a very good point actually, if Imay say. First of all, as I said earlier, the industry hasbeen investing billions of pounds for years in orderto accommodate this aspect. Indeed, and Christianis probably better-placed than I am because he isfrom Airbus, but, if you look at the performanceachieved on the Airbus 380 in terms of reduced

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noise, it is simply staggering, and I do not lose sightof Boeing working equally on this type of aspect, soI believe that, from a technological perspective, weare actually looking at noise abatement as part of theairframe, as part of the propulsion, the engine, andas part also of reducing the touch points with thelanding gear. You know, the noise is simply an eVectof the drag that an aircraft will create while landingat a certain altitude, given certain conditions, so a lotof things have been done and a lot of money hasbeen, and is still being, invested and I believe thatwith the latest development, if you look at the UK,actually we are leading and we are at the forefront onthe technological development roles of the enginewith what we call the “open rotor”, and that is notsaid enough. We have, as part of our own industry, aleadership position which has to be maintained anddeveloped further in order to actually comply with,and accommodate, these types of needs with thelimitations that we are facing.

Q190 Graham Stringer: I accept that there have beenterrific improvements made over the last 30 yearswith both the engines and the frames in the reductionof the noise, but how much further is there to go?Mr Esposito: Well, from my perspective, I think it isa trade-oV between how green one can be and whatimplication it has on safety, and that is where thetrade-oV has to be, as long as one evaluates clearlyand analyses positively what we all want. You know,the aviation sector is always depicted as people whodo not care about climate change, but, if anything,I believe that actually our industry is one of the topindustries in the world which cares very much andwe are investing in doing that, so it is not just words.I believe also that safety is paramount, and we saidit before, so one could push further the boundariesof the latest technical development up to where youstart to aVect the safety issues.Mr Dumas: I do not know where the limit is, but Ijust know that, if I had been told 20 years ago, “Thisis where you will be in 20 years’ time”, I would havesaid, “Oh, my God, it will be diYcult”, but weachieved it. What I am saying is that in Europe wehave the ACARE research objectives which are toreduce fuel burn and CO2 emissions by 50%compared to 2000 and noise by 50% as well, and weare working on those objectives. Whether we willachieve them or not, well, this is in 10 years’ time, butwe are working on them, and on the other side of theAtlantic they have similar objectives and enginemanufacturers have an equivalent objective as well.This is our business to reduce noise and to reducefuel consumption and then CO2 emissions, and onekilogram of fuel on board a plane means as muchpayload less and it is as much a cost for the airline,so we have to work on this. This is part of normalbusiness.Mr Brown: That is a really important point. Thedirect operating costs of our products is one of thekey diVerentiators in a sales campaign and this is awin-win for the industry because we understand thatevery pound of less fuel burned is lower operatingcosts, it benefits the environment and it is really asweet spot. Relative to your comment on noise, I do

not know how far we can go, but, if you look backover the last couple of decades, I can think back tothe 1960s of four-engine DC8s and clouds of blacksmoke, low bypass ratio engines and water injection,if you want to go far enough back. We have madetremendous progress continually on the enginefront. As airframers, we made real advances in the1970s and continue today with each new product asto how to package that power plant. I think you aregoing to see adaptive technologies, you are going tosee chevrons on the cells of our 787 and those willbecome active in order to further reduce noise, andI think we are becoming much more savvy on the bigintegration issues. Bruno talked about landing gearand we have been looking at putting fairings in thereand how we can fix leading-edge wind noise and howto integrate the propulsion system with the airframeand optimise that as a package, so we have come atremendous way, and again noise is a diVerentiatorin sales campaigns. We invest heavily in it, I knowAirbus does, and I think the push will continue.

Q191 Sir Peter Soulsby: I want to return briefly tosomething we touched on earlier about the benefitsof the next generation of ATM and SESAR, whichobviously you all have considerable hopes for. Iwould just like to get clarification from you aboutthe extent to which it is possible to get those benefitsthrough collaboration and agreement between themultiplicity of controllers that there are withinEurope, to what extent it is dependent on integrationof control within Europe to actually get thosebenefits, whether agreement and collaboration willget at least some of the benefits and to what extentwe have to have full or fuller integration to get allthe benefits?Mr Esposito: From my perspective, I would like hereto restate in answer to your question before mycolleagues take the floor that there is a gap here, asfar as I am concerned, which is that we have theSESAR Programme and that is bringing thetechnology that is necessary to accommodate theneeds and the requirements of our time, and then wehave another aspect which we should not, I believe,lose track of and that is the regulatoryimplementation, the European Single Sky. Here, Isee a gap myself between what the industry wouldlike and could achieve and what, as part of thisfragmentation that we have in Europe, to target justour region, we have to face. The fact remains thattoday we have a gap in between how far one iswilling to push the political will to accommodatewhat one can demonstrate we could achieve and Ithink that, if we were to have a bit more political willand to push further on the regulatory aspect, whatwe would be able to deliver on the technical aspectwould be saving time and complying a bit better withthe needs of the industry.

Q192 Chairman: When you say “political will”, areyou talking about governments or Europeanorganisations?Mr Esposito: I am speaking about both levels. I amspeaking of the European level obviously, but I amalso speaking of the national level, that the

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Government should actually perhaps emphasise abit more what we can achieve from a technicalperspective, and we have demonstrated a few things.If we are to achieve our target, we need actually tohave better compliance from the fragmentation thatwe were speaking of in terms of systems, proceduresand so on in Europe, and that would actually assistthe industry in being able to fulfil the targets.Mr Dumas: In Europe, we have the Single EuropeanSky Package 2 which, by the way, includes SESARas one of its four pillar, so those go together. Whenthe states can get rid of the SS package part, and thisis already done, they just need the agreement ofSESAR through NextGen, but what I would say isthat yes, we need some political support, especiallyat this time of crisis because, for the time being, weare looking a little bit at the short-term savings thatwe could achieve here and there, for very goodreasons and I am certainly not diminishing theimpact of them, but we need to think a little bitahead and develop our vision for 2020 and so on,which was done, so this is at the finishing phase withthe so-called “2020 Concept”. We need somecountries, some governments, to exercise someleadership, as was done in the definition phase wherewe, the consortium, went three or four times to meetthe UK CAA, and discuss how we can get moreinvolvement and more push from the UK becauseyou have got one of the most complex airspaces inEurope and you are the bridge, in terms of air traYc,between the USA and Europe and we really needpolitical support from the political process to pushand not simply look at what will happen over thenext three or four years. We need to develop this,what I call, “grand Victorian vision” for 2020.

Q193 Chairman: So it is vision and politicalleadership that you want?Mr Dumas: Yes.

Q194 Sir Peter Soulsby: Are you actually optimisticthat that can actually be achieved?Mr Dumas: What I would say is that some people atthe time of SESAR said, “You are not ambitiousenough”, and to say we were not ambitious enough,there were some technical solutions and politicalsolutions that we dropped because they said, “No,we have no chance to achieve this by 2020. What weneed is a date, so forget about technical solutionsand concepts, but we need to have planning, aprogramme that this is what can be done by 2020”,and whether it will be 2020, 2021 or 2022, I do notknow, I care less, but we are on the way, if I may say.Mr Brown: I resonate with Christian’s comments,that the risk today is that we will all see the economicdecline, the reduction in capacity of aviation and thecommunity will relax and this is no longer on thefront burner, but it needs to be on the front burner.I hope that Christian would agree with me that weare not moving fast enough and we were not movingfast enough before this crisis hit. We talked about thebig grand information-centric system of systems,and I think the opportunity for the UK is that theUK has one of, I think, the foundational workpackages in SESAR and it is relevant to your

particular issues here, advanced terminal airspacedesign and procedures. Again, I think there is a realopportunity to act locally and have a broader globalimpact by continuing to press on with some of theadvanced technologies that we have talked abouthere, and I think step one of that is to find out howto extract the value out of the capabilities of today’saeroplanes, and that is environmental andoperational, as there is fruit to be harvested.

Q195 Mr Wilshire: This issue of what opportunitythere is, I know I am risking putting words intosomebody’s mouth, but am I right in thinking thatthe message that I am getting is that there is morecapability in the aircraft you are now building thanexisting air traYc control is making use of and thatair traYc control, if changed, could do more withwhat you have already got in the air?Mr Esposito: Yes.Mr Dumas: Yes and no.Mr Wilshire: You would make a politician!

Q196 Chairman: Which is the yes?Mr Dumas: The yes is that short-term you areperfectly right. There are a number of functions onboard the plane that are not fully used or exploitedby air traYc control. Now, talking about the longer-term solution for 2020, the current aircraft, most ofthem, cannot do it.Mr Brown: I fully agree, but there are things we cando today.Mr Esposito: The problem we have is that we shouldhave a more pragmatic approach.

Q197 Mr Wilshire: Are the existing aircraft thatcannot do some of these things “retrofittable” withequipment?Mr Dumas: Yes, it is possible.Mr Brown: Yes, and I would also suggest, and thismay be a little unpopular, that we need to migratefrom an air traYc management paradigm, thehistorical paradigm, which was first come, firstserved, to a paradigm which says, “Best equipped,best served”. I think there will be levels of servicebased on the sophistication of the aircraft.Mr Dumas: If we do not do that, we will have realdiYculties in modernising the fleet because you willhave a mix of 6,000 aircraft, some equipped, somenot, so what would be the incentive for airlines toinvest in modernising their fleet or their cockpits?

Q198 Mr Wilshire: I would just ask one last one, if Imay, to take advantage of the fact that we have threepeople here who are not British and, therefore, donot have to automatically leap to our defence! Wekeep being told by people like NATS and others thatBritish air traYc control systems are probably anotch ahead of everybody else’s, that we run one ofthe best systems, and it, therefore, aggrieves me tohave to say that we ought to give more power toBrussels because I am quite keen to take a lot of itaway, but, if we do this, if we do go down the routeof some European integration, is there any risk thatwe are going to dumb down what we currently do, or

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are we right to be thinking, as Brits, that we do itquite well and will other people listen to us if we startjoining in?Mr Esposito: I happen to believe that yes, the UKindustry on several fronts should be seen as leaders.From a regulatory point of view, NATS, in myopinion, is doing terrific work, and the UK airspaceis one of the most saturated in the world, to keep thelevel of safety that we have, and let us not forget thataviation is one of the safest modes of transport, andwe go a long way by being innovative and applyinga great deal of skill in achieving that. On the UK’scapabilities in terms of manufacturing, we spokeabout what we are doing on the propulsion side, theengine, but let us not also forget that Airbus in theUK is actually working alongside another veryimportant key player, which is Bombardier, on whatwe call the “advanced material”, the composite, so,

from a manufacturing point of view, the UK isactually installed currently in a leadership role.What SBAC would like to see is actually us notlosing our key leadership position which could beover time fading away, if you allow me to use thisexpression, and taken on board by the newcomingmarkets, such as China and others, so I believe thatit is paramount that we do not give away to Brusselssome of our know-how just to sign a blank pagehere, that we participate and that we carry on theongoing dialogue, and that could be achievedthrough pressure put on the political level with theGovernment and also all the stakeholders from amanufacturing point of view or from an operationalpoint of view.Chairman: Well, thank you very much. I think youhave given us some excellent evidence, so thank youvery much.

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Wednesday 4 March 2009

Members present

Mrs Louise Ellman, in the Chair

Mr David Clelland Ms Angela C SmithMr Philip Hollobone Sir Peter SoulsbyMr John Leech Graham StringerMr Eric Martlew Mr David WilshireMark Pritchard

Witnesses: Captain Dean Plumb, Manager Technical Developments, British Airways, Mr GeoV Clark, Headof Flight Operations Regulatory AVairs, Virgin Atlantic Airways, and Mr Gerry O’Connell, AssistantDirector, Safety Operations and Infrastructure, Europe, International Air Transport Association, gaveevidence.

Chairman: Good afternoon, gentlemen. Can I askmembers if they have any interests to declare?Mr Clelland: Member of Unite.Mr Martlew: Member of GMB and Unite unions.Graham Stringer: Member of Unite.Ms Smith: Member of GMB.Chairman: Louise Ellman, member of Unite.Sir Peter Soulsby: I am a member of Unite as well.Mr Leech: Given the nature of the inquiry, I shoulddeclare a non-pecuniary beneficial interest in a pieceof land around Heathrow Airport.

Q199 Chairman: Gentlemen, could I ask you toidentify yourself, please, for our record?Captain Plumb: My name is Captain Dean Plumb,and I am Manager of Technical Development atBritish Airways.Mr Clark: GeoV Clark; I am Head of FlightOperations Regulatory AVairs for Virgin AtlanticAirways.Mr O’Connell: My name is Gerry O’Connell,representing the International Air TransportAssociation, 230 member airlines, and based inBrussels.

Q200 Chairman: Thank you very much. Yourindustry is facing major problems at the moment,particularly in relation to large reductions inpassenger numbers and with high oil prices. Do youthink that the Aviation White Paper’s forecasts forpassenger growth will actually be fulfilled?Mr Clark: Although you are quite right, I think weare seeing some extraordinary times at the moment,we feel that in the period of the White Paper, whichlooks ahead to 2030, the projections still feel right tous and this is seen as a temporary phase. Theindustry has always been cyclical, and this one issomewhat diVerent from the other cycles, but I thinkwe feel content that the overall projections in theWhite Paper are right.

Q201 Chairman: Is that view shared?Mr O’Connell: Yes.Captain Plumb: Yes, the same position for BA aswell when our projections go out. We are expectingconsiderable recovery of the current what we see as

a blip in the downturn for a 3% to 4% growth indemand—so, largely speaking, a doubling ofpassenger demand by 2030.

Q202 Chairman: The evidence from British Airways,Captain Plumb, says that Heathrow is unfairlydiscriminated against in the day-to-daymanagement of airspace. Could you tell us what thatmeans and what action you think should be taken?Captain Plumb: Certainly. I would like to answer intwo parts, if I could. The first part is around what wewould describe as avoidable disruption at Heathrowand the second part focuses on the actualmanagement of the airspace in response to thatdisruption. The core of our concern is that Heathrowoperates at 98.5%, largely, incapacity on a normalday. It is incredibly vulnerable to any disruption and,therefore, any pressure in the system, anyineYciencies in the system, really strike at theoperation at Heathrow itself. What we have seenhistorically is that a number of what we call minordisruptions would have occurred and have occurredbecause of things such as flight paths, ad hoc use ofthe airspace which seemed to fail to recognise thatHeathrow has got such a constrained and such apressured operation, and so we feel that actuallythere are some issues that we could address aroundHeathrow airspace which would recognise moreformally just how critical the operation is there. Atthe other end of the scale are events such as thePresidential visit last year. That had an impact on theoperation which lasted for three days. It had asignificant impact on both cancellations and delayedflights, a significant number of passengers wereaVected and, of course, there is the cost to the airlinesas well, and with that extreme of disruption to sucha pressurised airport, we feel that, potentially, thereis some opportunity in the future to look at otherairports that might be better able to deal with thattype of visit without having the same knock-oneVects. So that is the point in terms of disruption,avoidable disruption. I wanted to come on to talkabout the way that the airspace is managed, but Ithink there may be a couple of questions.

Q203 Chairman: No, I would like you to answerthat. You have put in the written evidence problemsabout the way airspace is managed, saying that

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Heathrow is discriminated against. I would like toknow who you hold responsible for that. Is it NATSor is it Eurocontrol?Captain Plumb: Let me give you the background towhy we have made that statement. There is atechnique used in airspace management called a“minimum departure interval” (an MDI). An MDIis an incredibly useful tactical tool, and what we aremost definitely not calling for is the removal of thattool. However, to give you some background on howan MDI works, if you can imagine either weather orintense pressure on a sector of airspace causing somepressure and causing bunching, what an MDI doesis it slows down the rate of departures from anairport, it deals primarily with weather andbunching in the immediate airspace around anairport. If that were to apply equally across thewhole of the London area, which logically should beaVected by airspace pressures and by weatherpressures in the same way, you would expect an evendispersal, but, looking back at the numbers for lastsummer, we have got a very diVerent picture acrossthe Heathrow Airport area and the other Londonairports. I have got an example, if I could share thatwith you. Last July, which is the worst month interms of amplifying the point, there were at Lutononly 12 MDIs imposed. You have got to rememberthat an MDI is eVectively putting your thumb overa running tap in terms of the traYc flow; so whilst itstops the flow temporarily and eases the pressure inone area, actually what it creates is a lot of pressureon the airport itself; it creates backward pressure. SoLuton had 12 MDIs, Stansted had 29, Gatwick had59, but Heathrow had 152 MDIs. If the principle istrue that this is a technique that is employed in theimmediate airspace and is not airport specific, thenit seems to be a recurring pattern over the evidencewe have got here in terms of the last 12 months, itseems to be the same proportion of MDIs applied atHeathrow. Our take on this is that Heathrow hassuch a large proportion of the traYc in the south-eastof the UK that it leads the decision-making processto say that one quick hit at Heathrow can remove alot of the pressure from the south-east.Unfortunately, the implication for that is thatHeathrow is the single airport that is least capable ofdealing with this backward pressure into the airport,so we do feel that there is disparity in terms of the useof MDIs. Our next concern around that is that, anMDI being a tactical tool, we have very littlevisibility about when MDIs are used. Certainly thathas improved over recent months and is somethingwe are very grateful for, but in terms of a reviewprocess and in terms of repeated use of MDIs, we cansee some patterns forming as well which kind ofsuggest there are other problems with the airspacethat we are not really getting to the bottom ofbecause we do not have this review process.

Q204 Chairman: Have you made any complaintsabout this at the CAA?Captain Plumb: We have been in discussion withNATS. We have got a great relationship with NATSand we work, we believe, very eVectively with them,but this is an area where the debate is still open.

Q205 Chairman: That is the channel that you havegot, with NATS rather than anywhere else?Captain Plumb: Yes, and, as I say, we are not in thesame ground at the moment, but this is an impact onHeathrow specifically and has a knock-on eVect tothe local airspace, or perhaps in reverse in the way Ihave described it.

Q206 Mr Leech: If the airspace was managed tooptimum capacity, what impact would that have oncapacity on the ground at Heathrow?Captain Plumb: Heathrow on the ground is runningmore smoothly now, so Terminal Five seems to havebedded in for us. The operation is still subject,however, to a number of ground delays. It is at itsmaximum capacity. Our take is that the airspace hassome historical ineYciencies. We could manage theairspace better, but there is no limitation in terms ofthe airspace, if I understand your question correctly,which stops us actually making best use ofdepartures from Heathrow.

Q207 Mr Leech: So there would be no impact on theactual capacity at Heathrow by improving theairspace. Is that the view you take?Captain Plumb: There probably is a link. It is quitedetailed, and there would be, technically, quite acomplex link between the two. What I would say isthat in terms of holding, stacking, at Heathrow, thatis a facility. Whilst we would like to avoid holdingwherever possible, what that does is that primes thepumps at Heathrow in terms of getting a veryeYcient landing rate, and actually your point in thatarea is bang on the money: because if you have gotan eYcient flow of aircraft readily available in thestacks to feed into Heathrow, then you get the mostsuccessful landing rate.

Q208 Mr Leech: Do the whole panel share that view?Mr Clark: In general, yes. Virgin Atlantic did notmake the specific point in our written submission,but I think the points made by Dean are veryrelevant and germane. What I would add to that isthat, clearly, there are issues with the groundinfrastructure at Heathrow which generate, forexample, holding following landing where there arenot enough stands and gates available for aeroplanesto dock, and we know that it is an issue, and if wecan increase the airspace utilisation and increase themovement rates, the ground infrastructure wouldinevitably be one of the choke points that wouldhave to be dealt with.

Q209 Mark Pritchard: You mentioned thedisruption at Heathrow due to the last Presidentialvisit from the United States. Given that we have gotthe G20 heads of government coming up on 1 and 2April, people coming in from all over the world, (1)is there a working group between NATS, yourselvesas leading airlines and BAA and (2) even if there isnot, what action has been taken to try and mitigatea repeat of the past?Captain Plumb: In terms of any working groups, Iam not aware of any specific group. What we havetaken the opportunity to do is highlight the impacts

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of the Presidential visit last year, and that has beenfed into the DFT, is my understanding as well.Clearly, NATS and BAA are aware of that and havetheir own data on the impacts as well. In terms ofwhat can happen for the future, I think we absolutelyneed to get the stakeholders involved and have alook at some alternatives. The Presidential visit isunique, because the implications of the way thePresident moves has a number of knock-on eVects toany airport he visits. It may be that the G20 issomething that Heathrow is capable of dealing with.My initial reaction, though, is that I would havethought it would put the same sort of pressures onthe airport and that an alternative location may bebetter for all the parties involved.

Q210 Mark Pritchard: Given that we are only a fewweeks oV, is it likely that an alternative location isgoing to be found? Certainly if there is not a workinggroup, there could be, but, by definition, you wouldthink the disruption is going to be greater, having 20heads of government rather than just one, althoughthat 20 does include, of course, the President of theUnited States. It is not for you, really, it is fortransport ministers and for the stakeholders inHeathrow, but you are the UK’s largest airline—itdoes have a massive impact on you, of course,depending on where Presidential aircraft actuallylands—but can you give a guarantee that thetravelling public over 1, 2 and 3 April are not goingto see a repeat of the disruption that they saw on thelast Presidential visit, and perhaps Mr Clark mightwant to comment as well?Captain Plumb: No, I cannot give that guarantee.What we would say, very strongly, is that we, like thetravelling public, are a customer of HeathrowAirport and very much a customer of the service thatis provided there. We have a very strong view that weshould not be disrupted, and we would stake thesame standpoint as the customers in that respect. Iwas not aware of the timescale for the G20, nor amI aware of their travelling arrangements, so I do notknow what the impacts would be, but we would lookto mitigate that in the future with every opportunitywe have got.

Q211 Mark Pritchard: We do not have a transportminister here, but, Mr Clark, if there was one here,what would you be saying in relation to what Ihave said?Mr Clark: I think what we would be saying is that wewould like to work with all parties, and that wouldobviously include, in terms of Heathrow, BAA, itwould involve working with NATS and the otherairlines, plus, perhaps, with MoD in terms of anymilitary activity in terms of military aircraftmovements, but I think what you are saying is whatcan we do to minimise that impact, and certainly itwould be diYcult for me, sitting here today, to saythat passengers will not be impacted during theperiod of that visit, assuming all the traYc is throughHeathrow. Will there be disruption? Inevitably, Iwould imagine, there will be, but we would want towork very closely and I think (I hope I would speakfor the majority of the operators) they will at an

operational level be working with those agencies totry and minimise the disruption, but clearly it is notan enviable position that we find ourselves in whensuch events take place.

Q212 Mr Clelland: Can you explain why, on a high-profile occasion like that, these high-profile visitorsshould be coming into Heathrow anyway? Why dothey not go to Brise Norton or somewhere like that?Captain Plumb: That is exactly the question wewould ask, and we would support a view that saysthose alternatives should be looked at.Mr Wilshire: The three submissions you have made,if I can summarise them like this (I think I amreasonably accurate): you do not like the strategy,you do not like the planning, you do not like thedecision-taking and you do not like the regulationseems to be a theme from all of it. What does theCAA and NATS do right?

Q213 Chairman: Who wants to answer that one?Throw us something positive.Mr O’Connell: If I could start, Chairman, on behalfof IATA. We are a global organisation, of course, butwe recognise the airspace in the United Kingdom isprobably one of the most complex in the whole ofEurope, and NATS does a very good job inmanaging the traYc volume. The CAA has veryimportant statutory responsibilities on safety andthese are discharged very eYciently. I think the pointwe are trying to make is we are looking at theTransport White Paper at 2030 and we have to planhead. It takes a long time to get the planning processright, and I think perhaps there are opportunities tosmarten up the process for changing airspace in theUnited Kingdom, particularly in the south-eastwhere the demand will rise as new runways areactually built. So our approach is not to be toocritical, our approach is to perhaps smarten up theactivities of achieving airspace changes safely andmore cost-eVectively.

Q214 Mr Wilshire: Shall we hear from Virgin andBA?Mr Clark: Certainly. You made the point that I thinkyou believe there are a number of negatives or thingsthat the airline or the industry does not like. I thinkthe things that we do like are the professionalism ofthe organisations as well. NATS are a veryprofessional organisation, the CAA is a veryprofessional organisation, and we have known thatfrom working with them for many years and I thinkin no way is that being challenged. What we arechallenging is the processes that bring all thosetogether, whether that is consultation processes orwhether it is the way that, for example, the Directorof Airspace Policy might work at the CAA orwhether it is the way that NATS might ultimatelyimplement procedures, but when you bring all ofthose parties together and all of that activitytogether, what we find ourselves with is an airspacechange procedure that does not seem to be able tocope with the demands of what we are asking it tocope with and, particularly looking ahead over the

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next 20 years or so, will it actually meet therequirements, and I think that is where our concernslie, certainly where Virgin Atlantic’s concerns lie.Captain Plumb: I would again echo the commentsabout the professionalism of the organisations weare working with. We have had a very goodexperience with both NATS, CAA, in fact UKMilitary as well, which we mention in oursubmission. Where we are in terms of our view is thatwe look at the UK airspace as being incrediblycomplex, it is under pressure and it has grown kindof organically over many years and has somehistorical ineYciencies. So, whilst the structures interms of airspace change that we are working withare populated by energetic and professional andforward-looking individuals, what we do not acceptis that we can improve the airspace or that we cannotimprove the processes that we use, and actually, Ithink, in terms of the airspace change process, as anoperator we are sometimes frustrated. We know wecan do more but some of the airspace and some ofthe change processes do hamper us slightly. There isa slight irony that those processes are there to makesure that change is carried out for the right reasons.An example I would draw on would be most of mytime over the last couple of years has been workingwith airports on things such as noise disturbance,and I have worked along with Manchester Airport.Manchester is one of the most forward-lookingairports that I have had the pleasure of dealing with.They take an evidence-based approach, they areforward-looking in terms of their engagement withairlines and what they have managed to do is to seek,with their stakeholders, some very positive changes.One issue that even Manchester has suVered with:there is a particular departure from runway 05, so itpoints to the north-east and requires a turn to the leftback towards the Wirral. It is called the Wallaseadeparture. The problem with that is it was drawnmany decades ago at speeds that aircraft simply donot fly at now. So for an eYcient departure, airlinesand pilots have to employ special procedures just tobe able to stay within the limits of that departuretrack. It is the consultation process, is myunderstanding, and some of the processes aroundchanging the ground track of that departure whichare causing a problem in terms of making what wewould suggest would be a very positive change inallowing that profile to be flown more easily andmore consistently. So we would point to thesuggestion that says actually there is quite atechnical depth of information that you have to gothrough in terms of consultation processes. I knowthat many people are concerned at the level oftechnical detail that has to be waded through. Wewould see a process that would be slightly more lightof foot, which would see stakeholders involved andunderstanding that a pilot or a trial flight departurewas being used and then we would go, at the end ofthe trial, into a consultation process that actuallyhad some evidence, you understood the impacts andyou could actually see, with first-hand experience,whether the trial had met the aims that it set out toachieve. Actually, I suspect we would find that sometrials would not be successful and that they would

not need to go forward to consultation because theywould not receive support. So, ultimately we wouldwant to see positive change. We think we can domore right now. We are very happy with the peoplewe are working with in the UK but actually we dobelieve we can move the processes on.

Q215 Mr Wilshire: Can I put to one side for a minutethe more general looking to the future. Let us stickwith the little bit you said about the professionalism,because in my mind I can see two things: what isgoing on now, which we need to be clear about, andthen what happens for the future? Is there anythingthat you want us to consider that your pilots areconcerned about? Forgetting it could be improved,but in terms of safety, security and professionalismof the moment is there anything that we should beconcerned about?Captain Plumb: At the moment, now, I have a highdegree of confidence in both the safety and thesecurity of UK aviation. You are asking a broadquestion; it is a very broad, general answer. There areno key airspace related issues that have a particularconcern. Where I think our concern is as anorganisation is that we see current pressure andactually growth in demand which is going to putmore pressure on the airspace, and that is why we areturning our gaze more to the future rather than thecurrent position.

Q216 Mr Wilshire: I want to come to back in amoment to that future, I just want to clear the deckson the current situation if anybody does have aconcern. Mr Clark, do you?Mr Clark: Not around the safety piece at all. We aremore than happy with that. We are only as safe as weare today, but we do not have any concerns on thatfront. I think it is really around where can weimprove eYciency, where can we improve thethroughput of the system and what can we do? Iknow a lot of people have spent a lot of time tryingto work with the infrastructure that we have. Weknow we only have a certain physical airspace towork with, we know we have a certain number ofairports and runway capacity to work with and weknow what the aeroplanes in the modern fleets cando, and many minds have been looking at that, butit is really about squeezing the extra amounts outthat we can, whether it is making routings moredirect, whether it is reducing time in the hold prior tolanding, whether it is stopping ground delays atHeathrow, Gatwick, Manchester, or wherever itmight be. It is really about trying to maximise thesystem that we have at the moment whilst, at thesame time, having one foot and one eye in what isprojecting forward and what is going forward. We allknow that hopefully before many years have passedwe will see more integration within the Europeanairspace—and perhaps we will talk about that lateron—but at the moment we are really concerningourselves on where can we maximise what we arecurrently working with.

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Q217 Mr Wilshire: Can I stick with the currentsituation for half a second? Is the relationship notnow with the companies but with the pilots? Is therelationship between NATS particularly and yourpilots satisfactory, open and accessible to both sides?Mr Clark: I would say certainly, and I think wehave avery good working relationship at a pilot levelbetween the pilots and the air traYc control oYcers. Ithink there is a good understanding. I think thatunderstanding has also built up over very many yearswhere you have established bases—Gatwick,Heathrow, Manchester, as far as our operations areconcerned—and there is this very great trust in eachother’s capabilities and each other’s way of working.Certainly we are blessed in the UK with a veryproficient and professional air traYc controlorganisation.Captain Plumb: We absolutely echo that. We runfamiliarisation flights for air traYc control oYcers asthey run through their training, we take them into thesimulator, and they reciprocate by taking our airlinepilots down to their ATC simulators. There is greatmutual respect and it is an incredibly valuableexchange.Sowedonothaveanyissues thereatall.Wehave an excellent relationship at a working level.

Q218 Mr Wilshire: If I move on to the broader issuesof the future and ask the same question, what is theworking relationship like between the airlines andNATS and the CAA when you come to discuss thesemore forward-looking issues: friendly, diYcult,relaxed, or what?CaptainPlumb: Iwould summarise it asprofessional.We accept that we do not always have commonground, but we work on it in a professional way tofocus on the facts and move forward constructively,and you would expect nothing less from anorganisation such as NATS and the CAA. I thinkthere seems to be a consensus growing to be a criticalmass which says actually our future in terms of UKairspace is very heavy dependent on a successfulSingle European Skies framework. We absolutely seethat if the UK is going to achieve its environmentaland flight eYciency target, we really must be able todeliver on that, and actually we see a lot of supportfrom NATS and within the CAA for that.Mr O’Connell: If I can add, Chairman, yes, inBrussels the UK is very active in promoting safe andcost-eVective Air traYc management, and it is verysubstantially engaged in all the programmes at thetechnical,operationaland regulatory level.Wherewedo have to make improvements across Europe is inthe environmental domain. Safety is very good;security is very good; however, there is a shortfall inthe environmental performance and we are lookingforward to all the Member States coming up withmore eVective processes to design airspace,harmonised at a European level, so that we can getsimilar procedures in use in most of Europe’sairspace, which is very congested and very complex.Sowewould like to see theseprogrammesacceleratedand Single European Sky introduced perhaps evenfaster than the dates which are being proposed at themoment.

Q219 Mr Wilshire: One question on what you havejust said, this question that our British air traYccontrol system plays a big part. One of the concernsthat has been expressed in previous inquiries and thatone hears from time to time is the possibility thatgoing for common European standards might resultin us dumbing down our existing standards. Is thereany substance in the argument that the Europeanstandard will be lower?Mr O’Connell: No, there is absolutely no evidence ofthis. On the contrary, the process is to raise safetystandards across the whole of Europe. If you look atthe performance of other States, there are severalshortfalls these are known by the authorities andrequire rectification. The objective of the SingleEuropean Sky is to bring these states up to higherstandards, standardswhichexisthere in theUKat themoment. So I see no evidence of dumping downstandards.

Q220 Mr Wilshire: Is that something that Virgin andBA agree with?Captain Plumb: Absolutely.Mr Clark: Yes, we would.

Q221 Ms Smith: Mr O’Connell, the IATA has saidthat a national airspace master plan would be highlybeneficial. Why is an airspace master plan soimportant?Mr O’Connell: I think it is important for severalreasons, one of which was mentioned in the WhitePaper 2003, that there should be a master plan, andclearly the parties are working on that. I think theimportance for this (and this is IATA’s submission),we favour a top-down approach, a forward lookingstrategic approach,whichputs inplace theprojects toplan the capacity of the future. If we had this masterplan and the Airspace Strategy, we would then havethe framework including the resources then we are ina very good shape to actually ensure that Britishairspace is fit for purpose in terms of the demandwhich we predict will exist at 2030. It takes a lot oftime to actually do this.

Q222 Ms Smith: In terms of a British nationalairspacemasterplan,howwould thatdovetail inwitha Single European Sky?Mr O’Connell: It would tailor in very well, because Ithink the UK CAA and NATS are very active inEurope. Indeed, they are a driving force forharmonisation of many developments in Europe. Wewould like to see this actually continued, because atthe endof thedaymymembers (230airlines) just lookat Europe as one large block of airspace and, clearly,the safety standards have to be the same throughoutall of Europe. So there are important connectionsincluding mechanisms which need to be madebetween the national master plan and the Europeanairspaceplan. I amcomfortable that this can bedone.

Q223 Ms Smith: NATS has begun scoping work on afuture airspace strategy for the Civil AviationAuthority. Are you satisfied that that work will meetyour expectations for a national airspace masterplan?

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Mr O’Connell: Before I hand over to my colleague,perhaps, who have more local knowledge andexperience of this, this activity is fundamental. Weknow that the design of airspace at the lowerairspace levels has been done very eVectively, withMinistry of Defence and NATS experts designingairspace. That is an essential component to makingairspace safe and obtaining a fair use of airspacebetween the various competing users oe. Indeed, thisis a model we would like to see rolled out across thewhole of Europe, but, again, Europe is not verysmart at designing airspace eYciently at the networklevel, which is why one of the core elements of SingleEuropean Sky II is the network manager approach,where we begin to move away from nationalairspace. We must begin to design airspace at a moreholistic level of the network and, to take on board allthe demands which exist at six or seven major airporthubs including the congested airspace in Europe.Our view is this is the way forward and I have nodoubt the UK will be very active in securing thecorrect balance between the network and the localuse of airspace.

Q224 Ms Smith: Are you suggesting that the UKcould lead in terms of breaking down the barriers interms of integrating European airspace?Mr O’Connell: What I am saying is there are somevery good practices in the UK, which could becopied across the rest of Europe, which wouldactually help Europe to address very complex issuesabout how we share airspace and design it safely. Sothere are opportunities, yes.

Q225 Ms Smith: Do you believe that other EUcountries, the rest of Europe, are prepared, are ready,in fact, to work on this integration?Mr O’Connell: I would certainly hope so. I knowthat the Single Sky Package II will place obligationson the Member States to ensure that this is donemore eVectively than the way we have done it inthe past.

Q226 Ms Smith: There is clear evidence that this isthe case.Mr O’Connell: I think so, yes.

Q227 Ms Smith: What kind of things must beincluded in the strategy to include airspacemanagement, do you think? What do we need to seein the master plan?Mr O’Connell: Certainly the way we share airspace,the way we look at congestion points. The south-eastof England, is the second most complicated airspacein the whole of Europe; so there are particularproblems in that area which can only be addressedby the experts who are familiar with the airspace. Sowhen we are proposing more centralisedmanagement of airspace in Europe, we are notsaying, “Oh, Brussels is telling people how to designairspace safely”, no, we certainly want a bottom-upprocess to actually secure the right expertiseenhancing the capacity into Heathrow, Stansteadand to Gatwick. This has to be done within a top-down process where, across the whole of Europe, we

are designing airspace to the same criteria and with aview to introducing the new technologies which willactually help us, these can only be introduced if thereis a more holistic and more harmonised approachacross Europe. I do not know if my colleagues wantto add anything.Mr Clark: Adding on to that, all I would say is thatyou mention the NATS Airspace Strategy. I do notintend this to be a criticism of NATS, but from ourpoint of view I do not think we have necessarily yetbeen privy to that plan and that strategy—it may bethat this is still to come—and so I think it would bediYcult to comment on that at this stage. All I wouldsay, though, is we do support the master planconcept, because otherwise we will continue withthis piecemeal, fragmented airspace planning,potentially, even under the Single European Skyregime. We realise we have got to work towards thismaster plan era, and it is still a plan, obviously, andthere will still be aspects that will need to be changedand amended, but if we have a master plan which wecan all work around, whether it is the operators orwhether it is NATS themselves or whether it is DFTor CAA, or whoever, we all know which direction weare working in and I think it would dovetail in withwhat is trying to be achieved across Europe.Captain Plumb: I would echo that. As yet, we havenot, as part of British Airways, become involved inthose discussions around future strategy. We areaware that some work appears to be going on in thebackground. We are mindful of the timescale. Therequirement was initiated in 2003 and we still seemto be looking forward to another two to three yearsof scoping before we get some substantive output,and we would like, as a major stakeholder, theairlines being major stakeholders in the use of theairspace, to be involved in a relatively shorttimescale, and that engagement has not happenedyet. So we would echo that actually an overallairspace master plan is a good thing for us toachieve. It would allow us to set-oV the competingpriorities for the airspace and the competing users ofthe airspace and would give us an opportunity toalign with Single European Skies.

Q228 Ms Smith: One last question. I understand thatyou think an airspace master plan is very important.However there are risks in terms of achieving that,the obvious risk being lack of co-operation betweenthe diVerent European countries, lack of leadership,lack of identification of who the leadership of such aplanning process should be. How critical is thedelivery of a master plan to the future use ofairspace? What is the risk of not delivering such amaster plan?Mr O’Connell: I think it is absolutely essential interms of the provision of capacity, safely and timly.It is absolutely essential that this master plan is arobust master plan and is supported by the nationalapproach to the way we manage airspace. Thiselement, together with the technical content of theAirspace Strategy and including the necessaryresources, is the basis for planning the whole of the

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United Kingdom’s airspace up to 2030, which Ithink was the view adopted in the White Paper in2003.

Q229 Ms Smith: As professionals, what do you thinkthe consequences might be if we fail to deliver?Captain Plumb: My view on that would be that wewould simply stifle the growth. We would not be ableto meet the demand in growth for Europe over thenext 20 years. We take a view that actually it is notthe number of passengers that create pressure on theair traYc system and infrastructure, it is actually thenumber of flights. They are broadly indicative, but itis specifically the number of flights. We are expectingthe demand for flights to get up to between 18 and20 million flights per year by 2030. We do not havethe capacity to deal with that at this current timewith European airspace, so the status quo will notmeet the demands for the future, probably not evenfor the next five to 10 years, if the truth be known.

Q230 Chairman: And the impact on safety?Captain Plumb: We would never actuallycompromise on safety. We would rather a flight didnot launch rather than compromise on safety; soactually the backward pressure would be that wewould simply fail to grow our operations; we wouldfail to meet the demand.

Q231 Chairman: The Competition Commission saysthat the major problem at Heathrow is from overscheduling of flights by the airlines rather thanNATS. Do you agree with that? Very briefly, do youagree with it?Mr Clark: From Virgin Atlantic’s point of view,obviously we only have access to a comparativelysmall number of slots at Heathrow, but we willmaximise the use of those. We operate largeaeroplanes, for example, solely on long-haul routes,but it really is about working with both the airportoperator, BAA, and NATS to try and ensure that wecan use every available second or every availablespare inch of Heathrow to maximise the throughput.Clearly, we do not operate in isolation; we can onlyoperate to the requirements as laid down by both theCAA, NATS and by the airport operator BAA; sowe are operating within those confines, as the otheroperators do. Is it busy? Yes. Is it congested? Yes, butit is safe, and I think we all learn to cope with thefoible that is Heathrow Airport.

Q232 Chairman: Captain Plumb, very, very briefly,do you agree with the Competition Commission’sconclusion in that respect?Captain Plumb: I would echo everything that GeoVhas mentioned. There is a partnership, so BAA plusairport users and NATS actually decide on thecapacity for Heathrow. We do see a time whenactually any extra capacity that is added atHeathrow, some of that should be garnered back forwhat we would call resilience. We see instability inthe operation because we are operating so close tocapacity, and so, as additional capacity is added, aproportion of that we would support being heldback for resilience.

Q233 Mark Pritchard: Two brief questions, the firstone to Captain Plumb and Mr Clark. Firstly, theinterface between civil and military aircraft use ofairspace in this country. I would be interested in yourcomments on whether you think that is workingwell, and talking about European integration andco-operation, Mr O’Connell, whether you thinksome of the military restrictions over mainlandEurope airspace should be a little bit more flexible,the French military being an example, and, MrClark, crowded airspace. Yes, there is an economicdownturn, but we have seen a sharp rise in the use ofprivate commercial jets over recent years. That maycome back in the medium term. I do not know howmany private movements are out of Heathrow, but ifthey were to be put in other airports, or designatedairports, or even non-major civil use airports, wouldit be helpful or unhelpful and would it have arevenue impact on somebody within the airportfamily? Captain Plumb.Captain Plumb: I think your question to me wasspecifically around the military civil interface. I aman ex-military pilot, so I would absolutely supportthe position that says we must invest in providinghighly eVective training opportunities for ourmilitary pilots. Where we do come back to is that theUK airspace has grown up organically and there is anatural jarring and competition for the use of whatare limited airspace resources between generalaviation, military and civil. We have got someexamples of where the interface maybe does notwork quite so well. We have numerous exampleswhere individuals within the military are veryprofessional in their approach to the use of airspaceand actually give us back danger areas, for example,to ease pressure on the system, but the structure thatwe all work within has these historical problems, andso the examples I would give would be: we connectto the UK as a very important stepping stone fortransatlantic flights, and the organisation of flightsacross the Atlantic is changed every day, there aresome set tracks. Those actually try to follow the bestwind conditions and so are relatively flexible fromday-to-day. What we do find is that UK civil aviationis concentrated on the spine of the UK and actuallythere are a number of danger areas, and the Welshmilitary training area, which, actually, given a blankpiece of paper, we would choose to fly straightthrough those areas to get access to the mosteVective and eYcient North Atlantic routings. So itis really important in terms of fuel andenvironmental performance because these are themost eYcient routings for the flights. We understandwhy those areas are there, but my personal view isthat if you had a military planner, a civil planner anda general aviation planner in a room and gave themthe UK to carve up today, you would end up withsome airspace that would look very diVerent fromwhere we are now. So we are entirely happy with theway that military airspace is given back and there issome flexibility around that, but actually there is anopportunity and a need to reinvigorate the work tosee if there is anything else we can do to release someof these pressure points.

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Q234 Mark Pritchard: Given the time, we will let theFrench oV the hook for a change in this space. MrClark.Mr Clark: I think your question was relating to theprivate jet operations, if I understood you correctly.I think, certainly at Heathrow and airports likeGatwick, the larger airports, over recent years therehas been a dwindling in the number of private jetoperations and I think they have been squeezed out.I guess we are not necessarily against that. The issuefor us really has two parts. One is what is happeningat the airports, and, clearly, we would advocate thata valuable airport slot is best used by a largeraeroplane rather than a small executive jet typeaircraft to maximise the throughput at the airport.So the airports are one aspect and, obviously, bytaking out those smaller movements, you do free upthose slots for larger aeroplanes to use. However, ifyou displace those business aeroplanes to the moreregional airports, or airports that perhaps surroundthe London area—Farnborough, Biggin Hill, forexample—they are still going to require airspace tooperate in and out of those airports, and so what wefinish up with is you are moving the problem perhapsfrom a ground congestion or airport congestionissue, in the south-east in particular, into an airspacecongestion issue. Those aeroplanes are still having toarrive and depart from those smaller, more regionalor business orientated airports, so moving themaround moves the problem, it does not take theproblem away.

Q235 Chairman: Do you agree with the Ministry ofDefence, who say that uncontrolled airspace is beingsqueezed?Mr Clark: Can I pick up that question first? I thinkprobably from a Ministry of Defence point of view,I can see how it is being squeezed, because I think, infairness to the Ministry of Defence, they have givenup more and more airspace to allow civil operations,whether that is on a temporary basis or a permanentbasis. I think the other thing is that there are certainparts of airspace in the UK where commercial flightthrough uncontrolled airspace is carried out, all be itto certain requirements, but I guess there is asympathetic view towards the MoD’s position thatactually they are being squeezed. We might arguethey are not being squeezed enough, but I can seewhy they might feel they are being squeezed, yes.

Q236 Mr Clelland: I have some questions on newand emerging technologies. You suggested thatairlines could use technologies and techniques toimprove flight eYciency were it not for the outdatedair traYc control procedures. What improvementscan be made?Mr O’Connell: There are a lot of developmentsunderway. There are certain navigation equipmentcapabilities, indeed, facilities we have on the aircraftwhich could help the controller by more precisenavigation, particularly in terminal airspace, butthere is also a very important SESAR project whichis now starting, and it is moving away from anairspace based approach to a trajectory basedapproach. The way we have historically used

airspace is controlled airspace and uncontrolledairspace, and some of these barriers will break downwith the new technology because to develop capacitysafely we have to have certain capabilities in both theair and the ground. Everybody who uses the networkmust have a certain capability to enable safety to beassured, and as these concepts are rolled out intoEurope up to 2020, we think technology has a hugerole to play, not only increasing capacity and notonly improving the environmental eYciency, wherewe have some diYculties at the moment, but alsoaddressing more optimum use of airspace, which wethink it is fundamental.

Q237 Mr Clelland: Where is the problem here? Is itNATS? Are NATS failing to invest correctly?Mr O’Connell: I do not think, with respect, it is acase of any one air navigation service provider notinvesting. One of the problems we have with theabsence of the Single European Sky is that there are38 air navigation service providers in Europe.Consequently, there are 38 investment programmesin Europe, and, if all these investment programmesare not aligned properly, we get the mismatch that wehave in Europe, which introduces manyineYciencies. This results in the unit cost of flying inEurope 70% higher than in the United States. Ofcourse, this is the reason why we urgently need aSingle European Sky initiative to harmonise andintegrate some activities as regards airspacemanagement in Europe.

Q238 Mr Clelland: So systems are more eYcient inother countries than they are here?Mr O’Connell: I think, to be honest, it is diYcult toanswer that question, because each of the 38 airnavigation service providers has their investmentprogramme. The importance of the SESAR projectis we begin to move towards a single concept ofoperation which means all the investmentprogrammes which will follow will be aligned at afixed point in time, and I think there we will get thebenefits in the future, but in the meantime we haveto use the models we have, which in 38 MemberStates, I can assure you, it is a very complexoperation managing the network in Europe.

Q239 Mr Clelland: Do you think that perhaps thepublic private partnership in NATS is causing a lackof long-term thinking?Mr O’Connell: I do not think there is any evidenceof that. NATS is engaged in its capital expenditureplanning and it responds to customer requirementsfor more eYcient airspace and, as a good airnavigation service provider, it will address the needsof our members flying into Europe.Captain Plumb: I would add to that that our recentfirst-hand experience has been quite the opposite tothe position you fear, which is actually NATS hassome strong leadership, it has got some clear focusand strategic focus and seems very energetic in itseVorts to invest wisely in technology in the future,and the level of engagement that we have seen with

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NATS on those subjects, in quite some detail, leavesus with a great deal of confidence that they have gottheir eyes on the horizon.

Q240 Mr Clelland: Can I ask about precision areanavigation. Who or what has prevented the benefitsof P-RNAV being achieved in nuclear airspace?Captain Plumb: P-R Navigation—eVectively it isusing technology that is already on the aircraft, andmost Western built aircraft over the last 20 years, Iwould suggest, are capable of these navigationstandards. What we have seen over the last 20 yearsis an increase in navigational accuracy but most ofour air traYc and routing regulations are not givencredit for that. We have been slow to take fulladvantage of this increasing capability but now newstandards have emerged so we have a standard in P-RNAV which allows for arrivals and departures atairports an accuracy—it sounds bad—of only plusor minus a mile. The demonstrated accuracy is muchmore accurate, especially with GPS equippedaircraft. You are talking about accuracy in tens ofmetres. The promise that P-RNAV has for us for thefuture is that you remove reliance on ground basednavigation aids and infrastructure. It is much moreflexible in terms of being able to redesign, makesmall and more frequent changes to procedures totry to fine tune the eYciency. It allows the pilots tostart thinking in 4D which is positions and timesover specific geographical or weigh point features.The promise is of more eYcient use of airspace withP-RNAV.

Q241 Mr Clelland: Should the operations at majorairports be limited to those aircraft which have topquality navigational systems?Captain Plumb: There is certainly an argument thatsays there is a minimum standard, a threshold belowwhich an aircraft should not operate into congestedairspace. There should be a mixture of both safetysystems and navigational systems and ultimatelycommunication systems with ATC as well. Mostwestern built aircraft fit those criteria quite easilyand indeed most European and east Europeanaircraft as well these days. Those standards are verywell monitored by the CAA and I do not think thereare too many aircraft that would fail to meet thoserequirements.

Q242 Mr Clelland: Should the CAA insist thatairspace designs must make optimal operational useof this equipment?Captain Plumb: The opportunity here is to use P-RNAV much more widely. It is a very flexible tool.Our own area is getting to grips with P-RNAV andall the opportunities that that oVers and there is anincreasing roll out of P-RNAV procedures. Wewould like to see that accelerated and we would liketo see much greater emphasis on it because of theflexibility of it.Mr O’Connell: At the European level the SESARmaster plan which we hope the Transport Councilwill adopt in Brussels at the end of this month, has afirst implementation package where PRNAV will beone of the elements, this will give us the assurance

that we can use airspace in a more environmentallyfriendly way with the use of this technology. I wouldhope that this programme could be rolled out acrossthe whole of Europe.

Q243 Mr Clelland: Will future technologicaladvances mean that you may have to change thetraditional fixed departure time model you operatein order to improve flight eYciency?Mr O’Connell: To improve flight eYciency manythings have to be done of which use of equipment isone. CDAs is another aspect. Eliminatingcongestion points in the network at European levelmeans a more harmonised approach to the design.All of these elements have to be done in a sequenced,packaged way. We want a single set of operatingprocedures for our pilots when they fly acrossEurope. I do not know if you want to add anything?Captain Plumb: I did not quite hear the question.Was it fixed departure times or points?

Q244 Mr Clelland: Yes. Would the traditionally fixeddeparture times you operate at the moment have tochange in order to improve flight eYciency?Captain Plumb: The fixed departure times that werun on our schedule at the moment are just astatement of intent. The reality is the operation isincredibly flexible.

Q245 Chairman: What makes it flexible? We weretold by NATS that technological changes wouldmean that take oVs may not be able to happen untillanding slots were known to be available. Is that thereason that there is flexibility now or is itsomething else?Captain Plumb: That is a development that I havenot been aware of.

Q246 Chairman: That was the point that was put tous when we visited Swanwick last week.Captain Plumb: I am sorry; I do not have anythingto add.Mr Wilshire: I find it fascinating that what I havealways believed to be a timetable is nothing morethan a wish list according to the evidence we havejust heard. Have you any plans to retitle it and stopcalling it a timetable?

Q247 Chairman: Let me ask you about the airspacechange process. All of you in your evidence makesuggestions about changes in the way in which theairspace change process is dealt with. Could I askyou all very briefly to say what is the most importantchange you would like to see?Captain Plumb: From the BA perspective, we thinkthere is positive change that we can make right now.We feel that there should be greater ability to accesspilot schemes, trial routings and do those withstakeholders, who then do those ahead of any formalconsultation. We feel it is a more logical sequence ofevents to achieve.

Q248 Chairman: Mr Clark, is there any one thingthat you would highlight?

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Mr Clark: We would like to see the process whichinvolves the consultation activities and how that isthen carried through in terms of how that isultimately managed. We find the process complex.We observe it to be complex. Clearly there have to besafety regimes in place to make sure that it isadequate but we feel a lighter touch could be used inthe way that airspace changes are introduced andplanned, so a lighter touch and less complexityshould be possible.Mr O’Connell: I would like to support mycolleagues: more of a top down managerialapproach, evidence based, which gives you theassurance that not only is safety being met butenvironmental eYciency can be improved. We haveto make a bigger eVort here.

Q249 Chairman: It has also been put to us that theCAA’s decision making responsibilities should betransferred to the Secretary of State for Transport orto the Environment Agency. Do any of you agreewith that?Mr O’Connell: This is such a specialised area. TheCivil Aviation Authority has built up a lot ofexpertise in managing and changing airspace. It is acomplex area. It involves interfaces with generalaviation, the military authorities etc., and we wouldlike that to be retained. Obviously it is a centre ofexpertise. If we were to go into parallel processesoutside of that, there is a risk of complicatingdecision making and not getting the improvementswe would like in terms of a smarter airspace changeprocess. IATA’s view is that probably the CivilAviation Authority is best equipped to managethese issues.Mr Clark: I think it should stay with the CAA.Captain Plumb: The point, as I understand it, for theEnvironment Agency becoming involved was aconcern that airspace decisions are 100%commercially biased. Our view is that that has neverbeen the case. We have always had this balance tostrike between commercial decisions and safetydecisions. Over the last two years airlines—Virginand BA and also airspace providers such as NATS—have taken on formal, public commitments towardstheir environmental aspirations. I believe the reason

Witnesses: Air Vice-Marshal Tim Anderson, Assistant Chief of the Air StaV, and Air Commodore MarkWordley, Director, Defence Airspace and Air TraYc Management, Ministry of Defence, gave evidence.

Q251 Chairman: Good afternoon, gentlemen. CouldI ask you to identify yourselves, please, for ourrecords?Air Vice-Marshal Anderson: I am Air Vice-MarshalTim Anderson, Assistant Chief of the Air StaV,Royal Air Force, and also the Secretary of State forDefence’s representative in the Civil AviationAuthority as a non-executive member of the CAAboard.Air Commodore Wordley: I am Air CommodoreMark Wordley and I am the head of the DefenceAirspace and the Air TraYc ManagementOrganisation.

that was first mooted is now largely obsolete becausethe environment is much higher on everybody’sagenda within the industry. In terms of the Secretaryof State, perhaps in the most diYcult of decisionsthere is a place for that role. I would be concernedthough. Why are we looking at airspace changepolicy? We are trying to get the best, most eYcientchange possible. What I would be concerned aboutis an attempt to use a tool to stifle change. Thatwould be my concern about the wrong approach orthe wrong level of decision making.

Q250 Chairman: Do any of you have any additionalthoughts on changes you would like to see on therelationships between the military and civil aviationto improve route eYciency? Is there any specificthing you would like to see?Mr O’Connell: There are very many good practiceswhich exist in the UK at the organisational level andin the way civil and military work together to designairspace so they can meet their own needs. This is amodel which could be rolled out across many partsof Europe where such proximity does not exist. It isvery important to get the environmental gains. Weneed the experts to sit down to design airspace in aprofessional way. This is an area where Europe couldmake lots of improvements. Also, within the UnitedKingdom itself, as we move towards greaterenvironmental requirements and shorter routes, wehave to have a smarter process in place for airspacechanges and use certain certain capabilities, both ingeneral aviation and in military and commercialaviation, so that we are all assured that the highestsafety standards can be maintained. That requires alot of planning and a lot of support processes.Captain Plumb: In terms of military airspace used,there have been attempts in the past to try to get abetter balance and meet the needs of both militaryand civil aviation users. We would welcome anyeVort to reinvigorate that and also for the structureand framework around that and a national airspacepolicy and strategy would be a useful vehicle forthat. We would be entirely satisfied that that wouldbe a good formula for being able to strike thosebalances.Chairman: Thank you very much for coming andanswering our questions.

Q252 Chairman: The written evidence you havesubmitted gives us the impression that you are verywell represented in airspace policy making and in airtraYc control. Why do you feel that you haveconcerns? Do you feel that you are not representedenough or that decisions are taken away from theareas that you are involved in?Air Vice-Marshal Anderson: I would not wish theevidence to suggest that we have concerns. I thinkthe balance would be more in the other direction incompany with the evidence you have just had. Wewould regard the relationship we have with the otherstakeholders in the aviation community, particularly

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in terms of airspace and air traYc management withthe Civil Aviation Authority and with NATS, in avery positive light. If there is concern it is more thatthe direction of travel, if you like, of air transportand aviation in general will inevitably place stresseson airspace and on airspace structures and we wouldclearly wish to ensure that our say in how thesestructures are developed is maintained at the sort oflevel that it is at the moment. The level it is at, at themoment, I think is very satisfactory.

Q253 Chairman: Are there any changes ininstitutional and consultative arrangements that youwould like to see?Air Vice-Marshal Anderson: No. The structures atthe moment are better than fit for purpose. TheMinistry of Defence is integrated across thehierarchy of policy and regulatory bodies in the CivilAviation Authority. Our relationship with the licenceholder, with NATS, is exceptionally good. We arealready involved quite eVectively in Europe andincreasingly so. We have good visibility ofdevelopments in terms of policy in that area. I couldnot point to anything at the moment which I think isa critical flaw in the structures or which we feel weare not being adequately represented in. That doesnot mean for a second to suggest that everythinggoes our way or we always get what we want, but Ithink we have rarely ever come away from a decisionpoint thinking that we have not been fairly heard.Air Commodore Wordley: To complement that, Iwould say that we are seeing signs that our militaryrequirement and position is being taken into accountto an even greater extent. The example I would giveis the development of the Functional AirspaceBlock, one of the European initiatives. From theNATS perspective and the UK perspective, civilside, there was an immediate recognition that a lot ofthe work would not be able to be moved forwardwithout military representation. I have been invitedand I sit on the management board of the UK/Ireland FAB and a number of my staV sit on thevarious working groups which inform the MoD’srequirements but also contribute to the wider debateto ensure that the UK’s interests in the Europeanagenda are met as far as possible.

Q254 Mark Pritchard: First of all, a personalcomment. The RAF are very welcome in Shropshire.RAF Shawbury neighbours my constituency butwith landing zones in my constituency. We welcomeyou there in the county. We heard earlier from one ofthe witnesses that the visit by the American Presidentlast year caused huge disruption at Heathrow and alot of it was covered in the media. One of mycolleagues suggested perhaps moving that sort offlight, with the G20 summit coming up and thepotential for more disruption. Is there any militaryreason why visiting heads of government could notland at Brise Norton and therefore minimise thedisruption to travelling passengers at Heathrow?Air Vice-Marshal Anderson: I think the movement ofany VIP, head of state, etc., depending on who theyare and under what circumstances they are moving,will have a multi-faceted equation to solve,

particularly in security terms. The role of themilitary in this area is basically to facilitate to thebest of our ability and within the resources we haveavailable that movement. Direction will come fromgovernment, the Foreign OYce, but not directlyfrom the Ministry of Defence. In the majority ofcases, we are basically a supporting act here. In termsof could the aircraft land at Brise Norton, physicallyyes, it could. Would that meet all of the variousrequirements of a visiting head of state? Would itmeet the requirements in protocol terms and so on ofour own government? I am not at liberty to commenton that.

Q255 Mark Pritchard: In airspace terms, would itdisrupt military operations? It certainly seemed todisrupt civil aviation operations.Air Vice-Marshal Anderson: I think it would bereasonable to assume that it would by virtue of thenature of the flight and the procedures that we wouldput in place.

Q256 Mark Pritchard: You are the Secretary ofState’s representative on a lot of transport issues, asyou outlined in your introduction. In principle,would you have any objection if there was a workinggroup set up for future heads of governmentcertainly when they are coming en masse to look atother locations and minimise impact on thetravelling public?Air Vice-Marshal Anderson: In principle I haveabsolutely no reservations in supporting whateverthe government requirement is.

Q257 Mark Pritchard: I am sure the Secretary ofState for Defence has noticed that as well. Movingon to wind farms, I am aware that wind farms clearlyhave an impact on radar and the Ministry of Defencedo from time to time object to planning applicationsfor that very reason and perhaps others. I justwondered whether you could think of an examplewhere an application that the MoD has objected tohas subsequently been approved and what trainingand/or operational impact that has had on youroperations.Air Vice-Marshal Anderson: As far as priorobjections being removed, that is a factor of theparticular environment that you are describing. TheeVect that wind farms have on radar and other partsof the environment is not a well understood science.It is something which the UK has taken a lead in. Wewere the first to identify that this phenomenonexisted. To the extent that relatively limitedresources have allowed, we have explored the impactof wind farms on radar capabilities. Whilst thatbody of knowledge has been building and whilst wehave been able to develop particularly the scientificbasis of that body of knowledge, in terms of nationalsecurity the principle has been “better safe thansorry”. In other words, where there is a doubt aboutthe eVect a wind farm might have for example on theairspace picture for the United Kingdom, we havetended to seek more evidence or suggest that thiswould not necessarily be a sensible thing to do at thisstage. Having said that, particularly recently in the

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last 18 months or so, I think things have movedforward in a very positive vector, partly because thedegree of understanding—the scientific basis and soon—is being enriched by some of the work we havebeen doing and partly also by an increasingwillingness, not to take risk, but to at leastacknowledge the very real imperative of thegovernment’s renewable energy targets and so onand the role that wind energy will play in that and thefact that we all have to exist on this island together.We have been more relaxed, shall we say, in terms ofsome of the restrictions that we would put in placerecently.

Q258 Mark Pritchard: Given that the Ministry ofDefence has not necessarily won every argument inevery case, surely that has had an impact? Otherwise,logically, you would not have made the argument inthe first place. Therefore, what impact has it had?Air Vice-Marshal Anderson: I may havemisunderstood your question. I thought it was a caseof us putting an objection in and then rescinding it.There are occasions where we have done that.

Q259 Mark Pritchard: No; where you have lost thecase.Air Vice-Marshal Anderson: There are examples ofthat by virtue of, in some cases, not being aware thata wind farm application was being approved locallyor whatever. We have been visited with wind farmson our doorstep which we have had to takemitigating action about. In the cases that I am awareof, this is more local disruption, having to amendtraYc patterns around an airfield because aparticular area in the vicinity is troubled by windfarm interference. What we have not experienced isany degradation from a national security perspectivein the overall airspace picture in the UK. Wherethese impacts have occurred, they have beenrelatively local. I would not wish to diminish theimpact but it is manageable.

Q260 Mark Pritchard: Finally, UAVs. It is not onlymilitary Unmanned Aerial Vehicles, but also agrowth in civilian use for mapping purposes andother purposes. I just wonder what your view is onthe growth of UAVs and what impact, if any, it hason your operations, both military and civilianUAVs.Air Vice-Marshal Anderson: The growth ishappening before our eyes. It does not mean to saythat the skies are full of them yet but we are movingto a point in the not too distant future where we willsee more of them because of the benefits they bringin terms of eYciencies and cost. The critical issue ishow you integrate them into airspace given that youdo not have people in them and therefore some of thesensors, not least the mark one eyeball that is usuallyrelied upon for deconfliction and so on, are notthere. A lot of work has been done recently by anindustry/government grouping under the termASTREA, which is looking at sense and avoid, howwe introduce into our systems the same degree ofsafety and collision avoidance that we wouldnormally expect in manned systems. We are not

anywhere near the point yet where we can releasethese things into the airspace and assume that theywill be able to look after themselves and not bumpinto anything, but there are some pleasing resultscoming out of that work which would give oneconfidence that the move from totally segregatedairspace into a more integrated approach withincontrolled airspace for example is not the stuV ofpipe dreams but is something which is potentiallywithin reach. Operationally, it is of littleconsequence to us because normally, when we areoperating as the military with unmanned airsystems, they are in operational airspace and therules and constraints are somewhat more relaxed inthat environment.

Q261 Chairman: Could you tell us what percentageof UK airspace is currently available to the MoD asclass G?Air Vice-Marshal Anderson: It is quite a diYcultquestion to answer. Some 60% of the UnitedKingdom’s airspace is controlled airspace. I use that60% in the two dimensional sense. Of course, it beingthe air environment, there is a third dimension totake into consideration and outside of the controlledairspace there are local areas of airspace that are notclass G. For example, the restricted zones round anairport or some danger areas or even some areas ofparticular natural significance. It is certainly nomore than 40%. It is probably considerably less andalso not all class G airspace is the same. By virtue ofthe topography as far as the military are concernedand what sort of training we get there, by virtue ofsome of the other environmental phenomena, notleast the weather factor, there is better quality classG airspace than others.

Q262 Ms Smith: Are any sections of airspace ringfenced so that they could not be converted intocontrolled airspace under any circumstances?Air Commodore Wordley: No. I do not think that isthe case. The UK takes the position from agovernment endorsed joint and integrated approachto air traYc management that we look at theairspace as inclusive, for anybody to use. In theextreme case, it could all be controlled airspace or itcould be completely the other way.

Q263 Ms Smith: Given what you have just said, inyour written evidence a statement was made aboutthe initial balance of conflicting priorities and thatthese should first and foremost be in line withnationally agreed strategic priorities. You quote theexample of perhaps economic priorities as opposedto national security interests. At the end of the day,a balance has to be struck. What is your view as towhat the priorities should be? What kinds ofnationally agreed strategic priorities should takepriority in the end?Air Vice-Marshal Anderson: It is diYcult,particularly for members of the military, to envisagethat national security would be anything other thanthe top priority in a real sense, if you take it to theultimate degree, but I do not think anybody, least ofall the military, would in any way counter the

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singular importance of the economic dimension tothe nation’s priorities. Rather than trying todetermine what a singular priority is, the key thing isto get a policy and regulatory framework whichinvolves all of the key stakeholders in a constructivemanner, whereby the various priorities can beidentified and accommodated in whatever is seen tobe the best way at the time. I think that exists today.I do not think it is so perfect that there are notdevelopments and improvements that we can make,but the way in which we, as the stakeholdercommunity in aviation, currently sit around thetable metaphorically and rationalise thesecompeting requirements for airspace usage is, as Ithink you heard in your previous evidence sessionhere, arguably a model that others should follow.The vector is in the right direction.

Q264 Ms Smith: You seem to be suggesting thatmore often than not this approach can resolvereasonably well some of the interests that couldpotentially conflict if this approach were not to betaken.Air Vice-Marshal Anderson: Absolutely.

Q265 Mr Martlew: My constituency is next to theLake District. For many years we had the issues oflow flying aircraft. The issue seems to have dieddown. Perhaps the numbers of low flying exerciseshave reduced or perhaps it is being shared more overthe rest of the country. What is the situation?Air Vice-Marshal Anderson: I think it is acombination of all of those factors. First andforemost, there has been a reduction overall in theamount of low flying. That is predicated on areducing number of aircraft within the militaryinventory and on a variety of diVerent capabilitieswhich we now develop and train, includingcapabilities at higher levels, higher altitudes.

Q266 Mr Martlew: Is this because the threat of warhas changed?Air Vice-Marshal Anderson: I do not think it isbecause the threat has changed. The sorts of thingsthat continue to drive us to train at low levels stillexist, but we have brought into our defencecapabilities or armoury a number of othertechniques and ways of doing our business, whichmean that we do not solely rely on low level flying todo all that we need to do. There is a more eVectiveuse of the low flying areas as well. There has been avery conscious eVort within the military to spreadour activities around and make sure there are nohotspots that are there merely by dint of us notpaying attention to what we are doing or trying ourbest to ensure that the training is spread around.There are a number of factors that have resulted inwhat has definitely manifested itself as a reductionoverall in low flying.

Q267 Sir Peter Soulsby: You very helpfully gave usan estimate of perhaps some 40% of airspace beinguncontrolled. We understood the diYculty ofestimating that. I wonder if you can give us adescription of how that is changing, how it has been

squeezed over recent times and indeed how you lookto the future, maintaining enough uncontrolledspace for you to use.Air Vice-Marshal Anderson: I will hand over to mycolleague to talk particularly about airspace changesthat have taken place and the degree to which wehave been engaged in them. I appreciate that you areperhaps simplifying the point about 40%. I do notwant to lose the point that it is not quite 40% offreedom. There is 40%1 which is in class A controlledairspace for civil air traYc but there is a variety ofdiVerent airspace blobs, if you like, around the restof the environment which limit the availability oftraining areas for example for the military or evenfor recreational flying for the general aviationcommunity.Air Commodore Wordley: Throughout the airspacechange proposal wherever it is, we are engagedthroughout that process so we are able to have ourvoice heard this is the absolute model which youhave heard previously that should be followed andsustained for the UK. There have been a number ofareas where we have seen some impact on our abilityor we have had to compromise. The move of theLondon TMA north into East Anglia was a goodexample where some of our bases—particularly theAmerican bases at Lakenheath and Mildenhall—were aVected to a certain extent, but again with theappropriate consultation and compromise we wereable to overcome those. The other area which hasalmost crept up on us is the growth of some of theregional airports. Many of them ironically are ex-military, of course. They have been developed forgood reasons from a commercial point of view intoa commercial going concern but then of course withthat generates either a zone or some sort of otherairspace put around the airfield. In many cases thereis also a growing argument that there should becontrolled airspace joining that airfield to the enroute sector. That is where from an MoD point ofview we argue that our own air traYc control systemcan and does handle that civilian traYc such that ourmilitary crews can continue to operate with thetactical freedom that they require, but at the sametime we are also contributing to the national eVort toensure that the commercial and economic side ofthat element of development is taken forward. It is,almost like the wind farm question, in isolation notreally an issue. It is the cumulative eVect of all ofthose aspects where we are increasingly having totake more and more notice and perhaps come upwith slightly harder compromise arrangements.

Q268 Sir Peter Soulsby: Are there particularregional airports that cause you concern?Air Commodore Wordley: Only from the point ofview of the geography, where the majority of theMoD’s flying bases are, down the east coast ofEngland. They are in certain cases I do not saycreating diYculties, but they require a certainamount of extra attention. Again, because of all theinterfaces we have at every level, I believe that safetyhas not been compromised. The operational

1 Note by witness: this should be 60%.

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eYciency of the commercial operation and indeedthe MoD operation has not been compromised.Other areas of the country where recently we havehanded over control of RAF St Mawgan down atNewquay to Cornwall County Council—that is anarea of the country, save for the Royal Navyestablishment down at Culdrose, which is not hugelypopulated with military airfields and therefore theimpact from our point of view is not quite as keenlyfelt. It does depend very much on which part of thecountry we are talking about.

Q269 Sir Peter Soulsby: Is there an argument forputting a cap on the growth of traYc at some ofthose airports to cover the issues you have raisedthere?Air Vice-Marshal Anderson: I do not think that wewould advocate at this stage, if you will forgive me,something as crude as putting a cap on. I think wewould be much more interested in continuing thedialogue that we currently enjoy and also lookingforward to technological advancements or eYcientuse of airspace, more intelligent use of airspace, sothat we can learn to grow together. The previousdiscussion on SESAR and the opportunities thatthat might bring, albeit it will not be tomorrow, givesome hope that if we continue to talk and manageour respective requirements in a mature manner thenwe perhaps avoid something as emotive as a cap. IfI go to Robin Hood Airport and say, “We intend toput a cap on your movements”, I doubt if I would geta very favourable reception.

Q270 Sir Peter Soulsby: There are not any exampleswhere you have not reached reasonable agreementsand compromises?Air Vice-Marshal Anderson: There are plenty ofexamples where we have not reached a conclusionthat is exactly what we set out to reach and we havenot enjoyed the full freedom or benefit of everythingwe try to achieve but, no, I do not think there isanywhere where we have walked away and thoughtwe have been really hard done by there. We recognisethat there are competing requirements. In some casesthere are higher priorities and, as long as we cancontinue to have this sensible dialogue, I think at theend of the day we will all end up with the correctanswers.

Q271 Mr Wilshire: There is an inevitable conflict Isuppose—it might be too strong a word—betweencivil aviation where its pilots understand that they gowhere they are allowed to go, when it suits somebodyelse’s idea of when they should go and your pilotswho want to go where they need to go—I am notcriticising them—when they judge it to be necessary.That is a fundamentally diVerent approach. To thatextent, what is the relationship on a day to day basis?In Swanwick, one senses an entirely diVerent feelbetween civil air traYc control and military. How dothey interface? EVectively, or is there pressure?Air Vice-Marshal Anderson: The expert on how theyinterface is sitting on my right so I will defer to himin a moment. I appreciate the caveat you placed onthe distinction between civilian pilots and military

pilots. At the end of the day, there is not a diVerentset of rules for each community. We are all, militaryor civil, applying airmanship and adopting the samerules. Our operations may lead us to operate more inclass G airspace where there is not such a restrictionon what you do and how you do it, but the way inwhich we get there, the way in which we conductourselves in that airspace, particularly when we arejoining our civilian colleagues in the route structure,is by the same principles and the same sort ofdoctrine. I know you were not suggesting this but Iwould hate anybody to think that we had acompletely diVerent perspective on how aircraftshould be operated in the airspace. I would like tothink that both communities operate to the samelevels of professionalism.Air Commodore Wordley: Whilst both communitiesare called “air traYc controllers”, if I can put it verycrudely, perhaps the driving of airlines down anairway is much the same as a lorry driver driving atruck down a motorway; whereas the military isdriving the Ferrari which needs to zoom in and outand do all sorts of other things. At one level—I thinkyou saw this at Swanwick—we literally have militarycontrollers sitting next to civil controllers. Thatenables the military task, which is more dynamic, inmany cases more demanding because of fuelpressures, sortie constraints and so on, to makemaximum use of their time and their fuel andtraining opportunities on one side of the country orthe other, depending on a number of diVerentfactors. The military controller has an innateunderstanding of what the military air crew need toachieve to fulfil their training or operationalmission. There is the overall understanding that firstof all the safety of the airspace is absolutelyparamount. As ACAS has mentioned, everybodyknows the rules are exactly the same, but it is just adiVerent way of discharging that particular role.Again, the relationship from my point of viewbetween military and civil controllers is really verygood.

Q272 Mr Wilshire: It could be argued that a civilaircraft flying in uncontrolled airspace is less safethan one flying in controlled airspace. Do you haveevidence that that contention is untrue?Air Vice-Marshal Anderson: I would be looking forevidence to say that it was true and none is apparentto me. A civil aircraft operating in uncontrolledairspace is operating under the same rules of the airin class G airspace under see and avoid, but theyhave available both on board technical systems andtraYc alert systems. They have access to airspaceradar services. It comes back to the point earlier onabout how the military and civilian air traYccommunities operate together. As you are wellaware, it is a joint and integrated airspace structureso we have military air traYckers providing radarservices both inside and outside controlled airspaceto civilian aircraft. We take civil air traYc servicesfrom NATS or from the military. I do not think thereis anything that suggests to me that any aircraft ismore vulnerable or at risk than any other operating

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in any of these types of airspace. There is nothingthat I would identify as being a significant riskfactor.Mr Wilshire: I am about to leave. I just want to makesure the witnesses do not think I am walking out indisgust in view of their answers.

Q273 Chairman: On what basis are you concernedthat future airspace strategy will be biased towardscommercial interests? You say that in your writtenevidence. Why do you think that?Air Vice-Marshal Anderson: I would amend thatelement of the written evidence slightly in responseto that question. I do not think there is a concernthat it will be. I think there is a concern that, if thestructures that we currently have in place or if therelationships which we currently enjoy were, forwhatever reason, to be distorted or changed, therelative priorities given to defence and nationalsecurity may not merit the same attention as they dotoday. There is no question about the economicimperative and the degree to which we need toaccommodate that for everybody’s benefit. It ismerely that we maintain this balance. Weunderstand that there is no one single priority at anyone time. There is a variety of priorities and theychange over time. They are dynamic and if wecontinue to have the dialogue then we are able toaccommodate that.

Q274 Chairman: Do you think that airspace changedocuments should have a specific reference tomilitary matters? Is that necessary?Air Vice-Marshal Anderson: Our involvement in theairspace change process in the positive light that Ihave described it thus far suggests to me thatwhenever an airspace change document is issued ourconcerns are either already accommodated in it orwill be as a result of consultation and so on. Again,I would not really ask for special treatment here.

Q275 Chairman: You do not see any need for anyspecific change?Air Commodore Wordley: I do not think so, no. Thehistory of the various airspace changes that havetaken place indicates that our views have been heardand, in some cases, taken account of. As long as thatarrangement continues, we would not argue forspecial treatment.

Q276 Chairman: Have there been any occasionswhen the Assistant Chief of Air StaV has referredCAA airspace change decisions to the Secretary ofState?Air Vice-Marshal Anderson: No.

Q277 Chairman: In relation to the SESARprogramme, what impact will that have on the UKmilitary?Air Vice-Marshal Anderson: Two potential impactsat least. The first is that we will benefit from what itdelivers if it does what it says on the tin. It is clearlynot going to happen overnight. There is a fairamount of technology development required. In myown opinion, I have some questions about thedegree of resources that will be put to it. Conceptsare easy to develop but funding them and developingthem can be more problematic. In the positive sense,we would look forward to SESAR as part of themodern airspace structure delivering benefits for allairspace users. The only other potential impact ofcourse is that, by virtue of what that technologyoVers, regulation or policy that subsequentlyrequires airspace users to adopt that technology willhave a price tag associated with it. It will therefore bea challenge for me and quite likely my successors toensure that those resources are made available fromthe Ministry of Defence.

Q278 Chairman: Do you think you will be able tofind those resources?Air Vice-Marshal Anderson: I cannot answer thatquestion until I know the scale of the challenge. Iknow for a fact that there is no extra money sloshingaround, just waiting for an orphan bid, but thestrength of our budget process is that we rank thepriorities and we fund those that we identify ascritical to our business or of high importance. I haveto assume that that process will take care of SESARwhen the time comes.

Q279 Chairman: Does that mean you expect to beable to meet the requirements of the programme?Air Vice-Marshal Anderson: I cannot expect to meetthem unless I know what the requirements are. Iexpect to want to be able to but, until I know howbig the cheque is I cannot make a comment now onwhether or not I will be able to sign it.Chairman: Thank you very much indeed for comingand answering our questions.

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Wednesday 18 March 2009

Members present

Mrs Louise Ellman, in the Chair

Mr David Clelland Ms Angela C. SmithMr Philip Hollobone Sir Peter SoulsbyMr John Leech Mr David WilshireMr Eric Martlew Sammy WilsonMark Pritchard

Witnesses: Mr Daniel Calleja-Crespo, Director of Air Transport and Mr Sven Halle, ATM Expert,Directorate-General for Energy and Transport, European Commission; Mr Alex Hendriks, CND DeputyDirector for Network Development and Mr Bernard Miaillier, CND Deputy Director for SESAR,Eurocontrol, gave evidence.

Chairman: Good afternoon. I would like to welcomeyou here and to thank you very much for agreeing tocome at short notice. We were hoping to meet all ofyou in Brussels but, as you know, because ofparliamentary duties, we were unable to come. Domembers have any interests to declare?Mr Clelland: Member of Unite.Ms Smith: Member of GMB.Chairman: I am a member of Unite.Sir Peter Soulsby: A member of Unite.Mr Leech: Given that we are talking about airspace,I will declare a beneficial, non-pecuniary interest ina piece of land around Heathrow Airport.

Q280 Chairman: Gentlemen, could I ask you toidentify yourselves for the record, please?Mr Calleja-Crespo: My name is Daniel Calleja. I amthe Director of Air Transport of the EuropeanCommission, and it is a privilege to be with youtoday.Mr Halle: My name is Sven Halle. I also work in theAir Transport Directorate of the EuropeanCommission, in the Single European Sky area.Mr Hendriks: My name is Alex Hendriks. I amDeputy Director for Network Development inEurocontrol.Mr Miaillier: My name is Bernard Miaillier. I amDeputy Director for the SESAR contribution inEurocontrol.

Q281 Chairman: You have given us evidence whichpoints out the extent of flight ineYciencies inEurope. Do you think that those ineYciencies couldbe resolved by improved airspace management?Who would like to give a view on that?Mr Hendriks: Perhaps I may be allowed to kick oV.Flight eYciency is basically composed of a numberof elements. We are talking about the eYciency withrespect to fuel; we are talking about the eYciencywith respect to the environment; but we are alsotalking about the eYciency of the ATC system. Thetwo normally may not be aligned 100% with eachother. This is where the SESAR programme comesin, to develop new technology that will enable thatto happen. Perhaps I can give you one brief example,Chairman. In order to make full utilisation ofrunway capacity, you need to have available acertain volume of aircraft in order to be fed onto the

runway. This means that the number of aircraft willbe in a holding pattern. We try to keep that as muchas possible to the minimum: by oVering en routedelay; by air traYc flow management; and, ofcourse, now with the SESAR programme—whichMr Calleja can talk about more—we hope to be ableto have more technology that will see to it thataircraft will flow from airport to airport, gate to gate,without any interruption and land precisely at thetime they are scheduled to land.

Q282 Chairman: Mr Calleja?Mr Calleja-Crespo: To complete Mr Hendriks’ reply,I would like to stress how significant the cost is whichEuropean industry is paying because of the presentfragmentation in air traYc management. Accordingto the studies we have, fragmentation of the airtraYc management results in additional costs of upto ƒ2 billion for airspace users. We think that if weimproved the European network design, which ispresently an amalgamation of national routes, ourflights could be more eYcient. We could even havesavings of an additional ƒ1.4 billion per year. Wecould also have significant environmental benefits.We could save up to 4.8 million tonnes of CO2

emissions per year with network improvements.Finally, we also think that we could have significantresults in reducing delays, which cost ƒ1.3 billion peryear. There is therefore a significant challenge inimproving the European air traYc managementsystem, and there can be very important benefits interms of fewer delays, environmental benefits, lesscost, better performance and, at the end of the day,a more eYcient European air transport system. Thisis the challenge and the purpose behind the action atthe level of the European Union and at the level ofEurocontrol.

Q283 Chairman: In the evidence we have receivedfrom the Commission you state very clearly that youfeel it is to do with individual countries looking attheir own networks that creates this problem. Is thisa special problem in the UK?Mr Calleja-Crespo: I think that to understand theissue you have to realise the evolution. In Europe wehave a single European aviation market. Weliberalised aviation and, since 1992, every carrier canfly freely from any point, from one country to

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another, with no restrictions. We have common ruleson slots, on ground handling, on airport charges; butin air traYc management we do not yet have a SingleEuropean Sky. We have a situation where air traYcmanagement has evolved from a nationalperspective, and the European Union only startedworking in this area in 2004. This is the first SingleEuropean Sky. One of the main elements of theSingle European Sky is the Functional AirspaceBlocks. What is Functional Airspace Blocks? It iscountries working together. The UK has been one ofthe most active countries in this area. TheFunctional Airspace Block between the UK andIreland is a way to tackle more eYciently thechallenges of fragmentation. In relation to the UK,therefore, I think that the initiative of the SingleEuropean Sky and the initiative of the FAB canbring very significant benefits. You should not forgetthat the UK has significant traYc flows to theEuropean mainland: 41% of traYc goes to or fromFrance; 25% to or from the Netherlands; 11% to orfrom Belgium; and, through Ireland, you have all theoceanic and transatlantic flights. We believe that, atthe end of the day, participating actively in theEuropean initiative of the Single European Sky, byworking together with other countries, by poolingresources, by managing the airspace more eYciently,will bring significant benefits. The London-Paris-Amsterdam triangle has both Europe’s densesttraYc and the busiest airports. There is hugeinterdependence between the UK airspace and theEuropean airspace. We are speaking about anetwork, and we need to have a very eYcientnetwork. Any problem in one part of the network—even if it is a small part—has a knock-on eVect on thenetwork. That is why we think that the UK has a lotto gain, like all the other Member States, by activelybuilding upon the European initiative of the SingleEuropean Sky.

Q284 Chairman: Do you think that the CAA andNATS are eVective organisations?Mr Calleja-Crespo: My personal opinion is yes, Ithink that we are impressed. The UK Civil AviationAuthority is a very active participant in the SingleEuropean Sky Committee. NATS was one of thefirst organisations in Europe to move forward withmodernisation. In a way, some of the schemes whichare being developed in the UK—the performancescheme—have brought inspiration for the Europeansystem; but, having said that, the Single EuropeanSky is a challenge for all the civil aviationorganisations. We believe that we can do better andthat we can implement more eYciently if wecontinue building upon the Single European Sky.This is why, as you probably know, we are discussingright now what we call the second Single EuropeanSky package, to make even more progress for thefuture.

Q285 Chairman: Mr Hendriks, did you want to addsomething to that?Mr Hendriks: I can perhaps add to what Mr Callejahas said, if I refer back to the previous question andthen come on to your last question, Madam

Chairman. I would like to endorse fully what MrCalleja has said. It is an evolutionary process.Whereas in the 1960s and early 1970s the states andthe service providers, to the extent that they existedthen, were very much inclined to plan their airspace,the route network and the systems purely on anational basis, we have moved away from that. I canlist six examples for you, if I may, of where we havebeen quite successful in Europe in the last few years,not least through the active and very positiveparticipation of UK CAA and UK NATS. Forinstance, the introduction of 8.33 kHz spacing forradios, making more frequencies available for aircontrol sectors, thus enabling us—and when I say“us” it is Eurocontrol and the service providers—tocreate more sectors and therefore more capacity.RVSM, reduced vertical separation minimum,where we moved from 2,000 feet vertical separationabove Flight Level 290—above 29,000 feet—to1,000 feet, creating six additional flight levels in thelevel of airspace where most jet aircraft would like tooperate. Europe was the first continental airspace inthe world to achieve this, and this was done on asingle day, at exactly the same time, for all of theEuropean countries. The third example I would giveis route network development. Whereas initiallystates and service providers were doing the routenetwork development purely by themselves, to acertain extent co-ordinated through ICAO, we nowhave a process in place where all the service providerswork together with us, and us with them, to come toa truly pan-European airspace. Air traYc flowmanagement has been centralised in Brussels, withthe co-operation of all the states. RNAV has beenintroduced, allowing aircraft to navigate, ratherthan from radio beacon to radio beacon, to anygeographical position. It is like GPS in all aircraft—enabling us to come up with a much more flexibleairspace. It was in fact a British and a French ideato come up with the flexible use of airspace. In otherwords, let us not treat airspace as civil airspace ormilitary airspace but, to the extent possible, let ussay that we have airspace, and civil and militarydemands must be accommodated there. Thoseinitiatives have enabled us to create significantcapacity in Europe in the last few years. Now wemove to the next phase, which is SES—the SingleEuropean Sky. Package no.2 has just come out,which will create more incentives and perhaps alsointroduce new technology. With respect to yourquestion regarding CAA and NATS, I can only saythat from a Eurocontrol point of view we haveexcellent relationships. The diVerence between CAAand NATS—one being the regulator and one beingthe service provider—has been an example for manystates to follow. It is therefore very positive.

Q286 Mark Pritchard: Sr Calleja, you mentioned theSingle European Sky. You also mentionedenvironmental benefits but also dealing with delaysthrough better, more improved air traYcmanagement. I wondered what your view was, andthat of the rest of our guests today, on the UKGovernment’s decision to build a third runway atHeathrow.

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Mr Calleja-Crespo: You have to understand that theEuropean Union works with respect to the principleof subsidiarity. It is impossible for us, from Brussels,to manage all the decisions taking place in thediVerent airports in the diVerent Member States. Webelieve that it is up to the local authorities, up to thenational governments—it is the principle ofproximity—in order to deal with these issues. Whatwe try to do from the European side is to agree thebasic principles with the Member States and toestablish the guidelines, the directives, which it isthen up to them to observe. Every time there is adecision to build a runway in one country of theEuropean Union, you have to reconcile twoconflicting principles. On the one hand, there is theprinciple of capacity. In the next 20 years we will befacing very serious problems of capacity in Europe.In spite of the present crisis, the forecast is that wewill have an increase of traYc which could be of 200to 250% from here to 2030. Europe needs to work onhaving more capacity. This is why the SingleEuropean Sky is so important; it is why havingairport capacity planifying in advance is a veryimportant issue. On the other hand, there is also theprinciple of environmental protection and how youreconcile the need for additional capacity and theneed to take into account the environmentalconcerns, which are extremely important andlegitimate and which also form part of the Europeanpriorities, which we are defending in very diYcultconditions on the international scene. What we haveagreed in the European Union, following ICAO—the International Civil Aviation Organizationstandards—is to follow the balanced approach.Every time there is a need to have some measureswhich have an impact on capacity, you have to do ittaking the circumstances into account: the needs ofthe local population, respect for environmentalconcerns, and consultation. These are the issueswhich Member States, at the right level—thenational government and the local authorities whoare responsible for airports in many countries—haveto fulfil. The European Commission does not havethe power in this area.

Q287 Mark Pritchard: You may not have the power,but I am sure that you have a view. In relation toreconciling dealing with capacity withenvironmental issues, do you believe the decision bythe UK Government successfully reconciles thosedivergent points?Mr Calleja-Crespo: I could not answer this question,because I have not followed in detail theconsultation, the process, or to what extent. I thinkthat it would not be professional on my side to do so.

Q288 Mark Pritchard: But you are the Director ofAir Transport within the directorate and, regardingthe Single European Sky, you have set those issuesout before us today. Surely you have a view whetherthe new runway would advance the principles of theSingle European Sky or not?Mr Calleja-Crespo: As I said, in view of thechallenges we have in terms of capacity and in viewof the congestion in some parts of Europe, and in

particular in the UK which is one of the densesttraYc, from a technical viewpoint the answer wouldbe that we need new airport capacity in Europe andwe need to planify the future. Of course, this newairport capacity has to be established, respecting theenvironmental and all the other legitimate concerns.However, the EU has no competence in planninginfrastructure. This is very important. MemberStates have very clearly said that this is not a matterfor Brussels. What the EU can do is to drawawareness to the needs. Last year, we established theEuropean Airport Capacity Observatory. This is anew and very important institution, where theMember States meet with Eurocontrol, theEuropean Commission, the representatives ofEuropean airports, airlines, consumers, regions, andwhere we will discuss the issues related to airportcapacity. It has just started its work. One of the firstthings we will do is an inventory on existing airportcapacity in Europe. Each country has its owninventory; we do not know what the actual situationis. We will analyse the evolution of traYc and we willthen be in a position better to assess the situation.This Observatory will not replace the nationaldecisions by countries, because that would gobeyond the principle of subsidiarity, which we haveto respect.

Q289 Mr Wilshire: I cannot resist the temptation,before I get to questions, to say how thrilled I was tohear someone from the European Commissionsay—and I wrote it down—“It is impossible forBrussels to manage everything”. I am thrilled to hearthat. I will hold you to it as well.Mr Calleja-Crespo: It is true.

Q290 Mr Wilshire: I want to move away for amoment from environment, delays, capacity andthose issues, and to ask you some questions aboutsafety. One of the requirements of Eurocontrol is tohave standardisation of arrangements acrossEurope, and that obviously means harmonisingstandards between individual countries. Again, oneof the objectives of the Single European Sky is tocreate a single safety framework. We, being Brits,have long since persuaded ourselves that, betweenthem, the CAA and NATS, as far as standards andsafety record are concerned, are amongst the best inthe world. Do you agree with that?Mr Calleja-Crespo: Yes.

Q291 Mr Wilshire: Yes is the answer—fine. Whenyou standardise and when you create a singleframework, therefore, can you assure us that underno circumstances whatsoever will any of ourstandards be diluted, to get your common policiesacross the European Union?Mr Calleja-Crespo: Yes, and I will explain why. Oneof the main pillars of the Single European Skysecond package is the safety pillar. We have thecapacity pillar, we have technology, and we also haveall aspects of performance. Safety cannot becompromised. You can have many parameters butthe absolute objective of safety has to be preserved—not only preserved but it has to be enhanced. We

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would not be launching the Single European Skyprocess if there were to be any consequences forsafety. Not only do we think that it will not bediminished but we also believe that it will bereinforced because, when you discuss safety issueswith experts, the key element is to have a total safetyapproach. What does this mean? It means that all theelements of the network have to have the higheststandards. If you have a breach in the system, youwill have a weak element in the chain and you willthen have a problem. What is the situation inEurope? In Europe you have Member States withvery eVective levels of aviation safety. Youmentioned the United Kingdom and I said that Iagreed. I also agree that we cannot manageeverything from Brussels, as I said! Coming to theissue of safety, what is very important is what theEuropean Commission is now proposing: that wewill have the European Aviation Safety Agency inCologne, which will do something that does not existnow. It will establish uniform, binding safetystandards throughout the EU. Why? Because wehave a single market and we need to have the highestsafety standards in our market. Having said that,what the Agency will do will be to establish bindingstandards; but these binding standards have to beimplemented at national level by the civil aviationauthorities. Therefore, I have no doubt that therecannot be a reduction in the safety standards. On thecontrary: we will have something that we do nothave now. Now we do not have common, bindingsafety standards. This will be enacted in all theelements by the European Commission, followingthe technical recommendations of EASA. EASA—the European Aviation Safety Agency—is composedof all the Member States and it will deliverrecommendations that afterwards will be enforcedthroughout the EU. This is a great improvement onthe present system, the Joint Aviation Authoritiessystem, where you do not have that. This is theadded value that the European community can give.We can have binding and enforceable safetystandards throughout the EU, and this is crucialfor safety.

Q292 Chairman: So it is a levelling-up, not alevelling-down?Mr Calleja-Crespo: It is a levelling-up—exactly.

Q293 Mr Wilshire: If I heard you correctly, you arearguing that it will be standards set centrally andstandards enforced locally.Mr Calleja-Crespo: Yes.

Q294 Mr Wilshire: I am thinking back to instanceswhere things have gone wrong. It is often theenforcement that has caused the trouble and thestandards across all the various nationalarrangements in Europe. Why can you persuadeyourself that it is sensible to allow enforcement to bein the hands of people who are not as good as theCAA and NATS?Mr Calleja-Crespo: I think that there is somemisunderstanding, because it will be the CAA andNATS which will enforce the standards.

Q295 Mr Wilshire: Yes, but they are the highestones. I am not going to name names, and I am surethat you do not want to name names, but you arevery aware that some of the air traYc controlstandards and systems across Europe leave a fair bitto be desired. You can set whatever standards youlike, surely, but if the same people are going toenforce them what is going to change?Mr Calleja-Crespo: So that you understand the logicthat we are proposing for the European side—andthis is a very important point—we will have, throughthe Single European Sky 2, a certain number of keyperformance targets that will be discussed by all theMember States and established at European level.Amongst them, we will have flight eYciency,capacity, environmental and safety standards. Thesesafety standards will be implemented at nationallevel. It will therefore be up to the nationalauthorities to ensure the achievement of thesestandards; to enforce these standards. In this respect,there should be no doubt that the whole approach isto level-up the existing situation. The advantagecompared to the present system is that we have thepossibility also for the European Union to checkwhether the standards are enforced or complied withat national level. The European Union has the legalpower to act and, if these standards are not met in aparticular Member State, we can start proceedings inrelation to this country and legally require thiscountry to enforce these standards.

Q296 Mr Wilshire: If you start from the premise thatI did, however, that British standards and Britishsafety are amongst the best in the world, it clearlyfollows that some are not amongst the best in theworld. I am quite sure that you are not going toemploy only Brits who come from the CAA and airtraYc control through NATS to set your standardsor to create a framework. Therefore, if you are goingto employ people who are not from amongst the bestin the world, what steps will you take and who willdo the training before you let these people loose ontelling us what we should be doing in the future?Mr Calleja-Crespo: To continue the description ofhow the system will work—in order to establishthese standards, the Commission will base itself onthe national plans arriving from the Member States.We will receive the standards from the UnitedKingdom. The United Kingdom will say, “These arethe standards which I intend to implement”. Thesestandards will be established at European level andthen implemented by the United Kingdom. I thinkthat there should be no concern in this respect,therefore, but I think that my colleague fromEurocontrol can complete this answer.Mr Hendriks: I would like to go back very briefly inhistory, if I may. We are convinced in Brussels,whether it is the Commission or Eurocontrol, thatthe United Kingdom has the highest safety levels.We are very much aware of what is going on. I amnot sure whether I am historically correct but, sinceClapham Junction, a lot has been done and you arein the forefront of running the safety programmes.In the past, in making the safety case for some of theprogrammes that I mentioned before, we have used

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British companies because they were in the lead inmaking the safety case and proving, beforeimplementation, that the system was safe. I believethat the higher level, as Mr Calleja indicated, raisingthe bar, will be the European norm. It is a matter ofthe safety oversight programme, which again isthrough EASA, through the Commission, that it willbe assured that the level will be applicable to all ofthe states.Mr Calleja-Crespo: I would like to conclude thepoint by saying something very important from theEuropean side. It is very good to have the highestsafety standards but, please, no complacency. Themoment you believe that you have the highest safetystandards and you are the best, you start to haveproblems. Safety is a permanent challenge and safetyrequires a big eVort, intervention on the part of allthe actors, and constant monitoring. We areensuring this through the European system, becausewe have auditing of the Member States throughEASA; we have annual reporting; and we haveanother safety committee which also protects ourcitizens through the “black list” process, which weare establishing at European level to take out ofEurope those airlines which do not have theappropriate safety standards. It is very good to havethe highest safety standards, but we have to continueworking and monitoring them permanently.Chairman: I can assure you that there is nocomplacency. What we are trying to establish is howthe European institutions will improve standards foreverybody. That is what we are trying to identify.

Q297 Ms Smith: I want to ask the panel what are themain causes of flight ineYciencies in Europe?Mr Hendriks: I think that I should turn the questionround, if I may. We have been trying to build asystem that fully meets the capacity, therequirements, for a number of flights to beaccommodated in the European system. That wasthe prime aim. Now that the fuel price is up, theemphasis is shifting from demanding capacity—nowthat we have enough capacity—to capacity withbetter eYciency and taking the environmentalaspects into account. We are now shifting toaccommodating the flight profiles that are muchmore the optimum flight profile, thus enhancing theeYciency of the system. For that we need ATC toolsand we need to be able to make use of the avionicson board the aircraft. I believe it is true to say thathistorically the avionics on board aircraft have beenyears ahead of ATC capability. In that sense it is verygood that we are now going into the SESARprogramme, because the SESAR programmeEurope-wide—there is also a close link with theUnited States’ NextGen system and Mr Calleja wasat a meeting with the Americans yesterday, so that itcould be a global system—is raising the bar for theability of the ground system to provide flight-eYcient profiles in addition to capacity, making fulluse of the avionic capability on board aircraft.Mr Calleja-Crespo: Perhaps I may add to MrHendriks’ reply. One of the main reasons for flightineYciency in Europe is that, in the Commission’sview, air traYc management sectors and routes are

still designed along national borders rather thantraYc flows. Air traYc control centres are belowoptimum economic size. We have duplication ofsystems, piecemeal procurement, high contingency,training and administrative costs. An aeroplaneflying from Athens to Helsinki on average does 50kilometres, and in some cases 100 kilometres, morethan it should because of the fragmentation of theEuropean airspace. It does not follow a straightpath; it has to follow a very complex route becauseof the fragmentation. This is why one of the ways toaddress this ineYciency, which is harming oursystem for all the reasons we have said—delays,environment—is to achieve a more integrated ATMEuropean system.

Q298 Ms Smith: Do you believe that ineYcienciescan only be improved if there is a centralisation of airtraYc control in Brussels?Mr Calleja-Crespo: No. We think that problemswhich are complex require complex solutions. Itwould be very easy to say, “You just create a central. . . .”—no. The problem has to be addressed, in ourview, in four diVerent ways. I would add a fifth oneat the end, which is the most important one. First,performance. We need to increase the performanceof the European air traYc management system. It isnot performing as it should. It is below average. Wewant to have the highest standards in safety and alsoin air traYc management performance. Second,safety. We have discussed the total safety approachthat we would like to put in place. Third, we need tohave more capacity in the air traYc managementnetwork; not only in the air, through the SingleEuropean Sky, but also on the ground. That is whyit is so important to develop additional airportcapacity. If we do not have more capacity on theground, increasing the capacity in the air will notwork. The fourth element is the technology. In thefuture, technology has to deliver more significantbenefits for us. We will have more capacity; we willalso have more eYciency. The fifth element,however, which is more important than the otherfour, is the human factor. The human factor iscritical. The training of air traYc controllers, theinvolvement of the social partners, trying to do thisin partnership—not only with the Member Statesbut also with the whole industry, the airports, theairlines, air navigation service providers, air traYccontrol—are essential. If we do not have the fivepillars, these five elements working together, it willnot work.

Q299 Ms Smith: I can see the point you make aboutthe five pillars, but I still do not see how theestablishment and sustaining those pillars, if youlike, will be achieved unless you have some form ofco-ordination, some form of direction, fromsomewhere. I think that the question remains,therefore. How will that be done? How will that beachieved?Mr Calleja-Crespo: There I come to what we call thenetwork management function, which is one of theelements we are taking into account. Through theSingle European Sky 1 process we have established

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what we call a “bottom-up approach”. What is thisapproach? Countries are getting together, they arepooling resources, and they are managing theirairspace. This is the Functional Airspace Blocks. Wenow have in Europe—and Eurocontrol can provideyou with more details—nine initiatives underway tocreate nine FABs. In Amsterdam yesterday, theSpanish and the Portuguese signed their South-WestEurope FAB. The UK and Ireland were the first. InJune 2008 they launched the UK-Ireland FAB. Sixcountries in central Europe—France, Germany,Belgium, the Netherlands, Luxembourg andSweden—are launching the Central Europe FAB.We have in south-east Europe a certain number ofinitiatives—Blue Med, the Balkans, Danube, theNordic FAB. All these FABs are a genuine eVortfrom Member States to do better and jointly to pooltheir resources. All this will provide animprovement, but we still need the network logic.There has to be someone who has the possibility tohave the overall vision; to reinforce co-ordinationbetween the FABs; to assist the air navigation serviceproviders in improving the overall eYciency; tomanage a certain number of technical elements—co-ordination of frequencies, management of scarceresources—and to have the overall vision of thearchitecture and route design. This is why in theSingle European Sky 2 we say that there has to be anetwork management function. Why? Because thepieces have to fit. The logic of network is so strong inthe Single European Sky that you need this function.Who could do this network management function?We have an organisation in Europe, Eurocontrol,which has the expertise, the technical knowledge, thebest experts—pan-European, not only EU-27 but 38countries which have been developing this. TheEuropean Commission’s proposal is to empowerand strengthen Eurocontrol management powers, inorder to make the system work. I am speaking aboutEurocontrol and I should perhaps apologise,because it is Eurocontrol who could give you someof the answers more directly—if you agree, MadamChairman.

Q300 Chairman: Yes, and could you tell us, MrHendriks, how the network management functionwould change Eurocontrol’s role?Mr Hendriks: First of all, I would like to re-emphasise what Mr Calleja has said: that theFunctional Airspace Blocks are a very importantinitiative. To a large extent, it is a bottom-upapproach, where the air navigation service providershave taken a significant lead and have gone out oftheir way to try to create an environment in whichthe aircraft can operate away from national borders.This was the idea of a Single European Sky, so thata truly European airspace could be developed. TheUK-Ireland FAB is a good example of that. As MrCalleja has said, there are others to follow. There isonly one concern perhaps: that we must now ensurethat, whereas in the old days we had nationalborders which to a large extent dictated the ATMenvironment, the FAB itself should not become thenew border. We need a process, therefore, so thatthere is adequate co-ordination between the FABs.

With respect to network management, we are awareof the European Commission’s ideas; we supportthem; we are awaiting the formal request from theCommission to develop ideas and to put forward tothe Commission how we should put that in place.For the time being we consider that there are anumber of elements associated with that; so it is notreally a person but a function. The function willcomprise network design, where, together with allthe service providers, we provide a catalyst or afacilitator to create a truly pan-European airspacedesign. There is a little caveat that I would like to puton the table: that, when you go into the specifics ofterminal airspace design, the best experts are at thenational level. We must therefore make full use ofpeople at the national level. There are then networkoperations, which are the day-to-day operations ofthe network. Flagging up if there are inconsistencies,if there are bottlenecks in the system, so that it canbe fed back to the network development. There is aperformance review that needs to be done, and anindependent audit function. Basically, those are thefour functions that for the time being we see formingpart of the network management function. It is theintention that, once we receive the invitation fromthe Commission to put forward proposals, we will,as we have done with any mandate from theCommission, carry out extensive stakeholderconsultation prior to submitting those proposals tothe European Commission.

Q301 Ms Smith: My final question is about anyproposed accountability or governance forEurocontrol, if it were to gain these very importantfunctions. The Single European Sky has greatpolitical implications. Can you give me the latestthinking on how Eurocontrol would be governedand made accountable for its functions?Mr Calleja-Crespo: I think the question is forEurocontrol but, from the European Commission, Ican say that we are watching very closely theprogramme of reform of Eurocontrol—transforming Eurocontrol into a very eYcient andvery active organisation. I think that there are alsoimprovements in the governance, with theparticipation of the stakeholders and newinstitutions. However, I think it is more for MrHendriks to reply to this.Mr Hendriks: Eurocontrol is basically anintergovernmental organisation; so our owners arethe governments. We are now in a situation where weare transforming it, to give full recognition to thefact that at the national level air traYc control is nowhandled through independent privatised/corporatized—it depends a little bit on thecountry—air navigation service providers. They arevery important stakeholders. We have the airnavigation boards, where the air navigation serviceproviders actively participate and have a say in howwe progress, but we remain an organisation basicallyof the governments, of the states. Our highestdecision-making body is the Provisional Council—abody where ministers or DGCAs like Sir Roy would

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sit—and, more and more, we are moving to asituation where we become the technical arm onATC of the European Commission.

Q302 Chairman: Could the network managementfunction overrule the national regulators?Mr Hendriks: Within the powers given by thetransport ministers to the European Commission, itwould be with the Commission.

Q303 Chairman: Can you tell us that, Mr Calleja? Itis trying to work out what the respective power of thediVerent organisations would be.Mr Calleja-Crespo: I think that this is a veryimportant point. In our scheme as proposed by theCommission—the Commission proposes, then it hasto be discussed by the Member States, by theEuropean Parliament and then, if the Member Statesand the European Parliament agree, this wouldbecome legislation—the proposal would be that wewould have this network management function. Avery strong function, to co-ordinate the FABs, toparticipate in the design, to contribute to managingthe whole network system. This is a decision thatwould be taken by Eurocontrol, who would beempowered to perform this function. Who isEurocontrol? Eurocontrol is the Member States. It isthe Provisional Council of Eurocontrol where theMember States sit. Member States would have toagree; would have to decide. We would have theexperts from the diVerent countries discussing theissues, deciding what are the best alternatives and, atthe end of the day, there would be a decision. Thisdecision would simply be a recommendationaddressed to the countries, which they could followor not. It will remain a purely intergovernmentalsystem. If we want a system to work more eYciently,the proposal of the Commission is that there shouldbe an overall assessment of the way the systemworks. This is why, together with the networkmanagement function, we would have theperformance review body. This would be a body thatwould report regularly on how the European airmanagement system is working—have we donebetter this year and have the targets been met?—andwhich will provide recommendations on the system.

Q304 Chairman: How would it actually co-ordinatewith, let us say, NATS? Not in terms of assessingwhat has happened but in operations.Mr Calleja-Crespo: Through the Single EuropeanSky Committee, where you have the civil andmilitary representatives from each country. It wouldbe the Single European Sky Committee which woulddecide at the end of it.Chairman: Do any of the other members want to aska question on this topic?Mr Wilshire: Yes, on this precise question. You wereasked a very straightforward and simple question.Would you be able to overrule national regulators?What we got was a very longwinded non-answer.That question is capable of the answer “Yes, youwould be able to overrule” or “No, you wouldn’t”.Which is it?Chairman: Can you help us with that?

Q305 Ms Smith: Operationally.Mr Calleja-Crespo: I am trying to think of what areaor a specific case where we would overrule. I amtrying to think of an example to give you. We havethis manager of the network system who willoverview the situation and, for example, there is adisagreement with a national authority—this is thekind of situation you are thinking of? Would thenetwork manager function be able to overrule andimpose a decision on the national authority? This isthe question?

Q306 Chairman: This is one of the areas.Mr Calleja-Crespo: I do not think, in the presentdiscussions with the Member States, we havereached this level.Chairman: So that has not yet been discussed.

Q307 Mr Wilshire: The answer is that you do notknow.Mr Calleja-Crespo: No. The answer is no, I do notthink that the network manager could overrule,because the network manager has functions of co-ordination. He does not have decision-makingpowers in relation to the national authorities.

Q308 Mr Wilshire: The national authorities can goon doing whatever they like; so what is the point ofsetting up another bureaucracy?Mr Calleja-Crespo: No, we are discussing twodiVerent things. One is the management of thesystem. The network management function will beable to co-ordinate; will be able to allocate the scarceresources; will co-ordinate the functioning of theFABs; but the network manager cannot say to acountry, “This is not the right FAB”. The FAB iscreated by the sovereign Member States. We cannotsay from Europe, “No, this is not the right FAB. TheUK and Ireland cannot do their FAB”. This is notpossible.

Q309 Chairman: You are saying that it cannotoverrule.Mr Calleja-Crespo: No.

Q310 Mr Leech: The estimated cost of implementingthe SESAR programme is ƒ30 billion. Given thecurrent financial climate in the industry, is there anyrisk to the implementation?Mr Miaillier: This cost of ƒ30 billion should be seenas including not only the new capabilities that areproposed in the context of the SESAR programmeand that have been proposed recently; it should alsobe seen as including the cost of simply maintainingthe current system capabilities and developing themas much as possible, in the light of the increasingtraYc. We have presented the ƒ30 billion as beingwhat the total bill for the development of air traYcmanagement to accommodate the future traYcdemand will cost. If SESAR did not exist, quitesubstantial investments would still be necessarysimply to follow the eVects of traYc, and maybe noteven be able to accommodate the traYc demand.With SESAR, we will in fact have more eYcientsolutions. For example, with the generalised use of

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the Galileo accurate navigation system, we can getrid of part of the infrastructure, which is currentlyavailable and maintained on a day-to-day basis onthe ground, of the more traditional navigation aids.By moving to SESAR, therefore, we can also reducecurrent infrastructure costs and improve the overallcost eYciency of the system.

Q311 Mr Leech: I think that what you are saying isthat ultimately it is a cost saving and therefore thereis no risk attached, because these costs wouldhappen anyway.Mr Miaillier: Any decision in the context of SESARwill be subject to a business case that will considerthe cost eVectiveness of a new capability, also itssafety aspects, the environmental case and thesecurity case. This will therefore be the subject of thebusiness case presented to the diVerent stakeholders,before the actual implementation decision is made.Definitely there is a high cost, because it implies newsystems on the ground and in the aircraft. Themajority of the costs are on the aircraft side.However, we want to make sure that any decision togo to a higher level of capability pays back in areasonable amount of time, so that it is aVordable,by the airlines in particular, and progress will bebased on cost eVectiveness.

Q312 Mr Leech: Are there any contingency plans inplace in the event of the money for the SESARprogramme not being forthcoming?Mr Miaillier: There are plenty of risk factorsassociated with the SESAR programme, because it isquite an ambitious programme and because we arestill in the validation stage of a number of theelements that belong to the programme. Not all thedecisions will therefore be made today; they will bemade progressively when we have the results ofresearch. At each key point in the decision-makingprocess we will consider whether, for each of theenvisaged capabilities, the answer is positive;whether we have a positive business case andwhether we can move. This will be a continuingprocess, which will also minimise the risks taken atany given moment in time.

Q313 Mr Leech: Did you want to add something,Mr Calleja?Mr Calleja-Crespo: I wanted to come back toprovide the Committee with the fullest informationon the previous point. You are now discussingSESAR. If the Chair would allow, I would like to—

Q314 Chairman: Yes.Mr Calleja-Crespo: Because I think that we are hereto provide the maximum information and to giveyou all the elements. To come back to the issue of thenetwork manager and whether or not it can overrule,I have been checking the present state ofdiscussion—you have to understand that this is aproposal which is now under discussion by thecommunity institutions—and the answer, even moreclearly than before, is no, it cannot overrule. The airtraYc management network function has thepurpose of supporting initiatives at national level

and at the level of FABs, and “ . . . the abovefunctions shall not involve the adoption of bindingmeasures”—I am reading—“or of general scope orthe exercise of political discretion. They shall takeinto account proposals established at national leveland they shall be performed in co-ordination withthe military authorities”. It cannot overrule,therefore.

Q315 Chairman: That is a definitive ruling,therefore.Mr Calleja-Crespo: This is the text of the provisionswhich are now under discussion on the networkmanagement function, and there is no intention thatit can overrule. Even to overrule the military—no,this would not be possible. It is not the approach.

Q316 Mr Leech: I was going to go on to newtechnologies. Eurocontrol describes the applicationof advanced navigation capabilities as a must.Should operations at major airports be limited toaircraft carrying top-quality navigational systems?Mr Hendriks: With respect to advanced navigationcapabilities, more and more there is a move towardsaccommodating more and more flights into theairspace. We are talking about terminal airspace inthis case, but it is equally applicable to the onwardairspace. Under the old regime, that would havemeant more and more navigational beacons. Nowwe are going into RNAV, precision RNAV and itsadvanced applications. That will allow aircraft to beseparated with less distance than is currently thecase. It will allow a higher capacity as well as bettereYciency of the system and, as a by-product of that,less fuel burn. That programme will work only if allaircraft are capable of meeting that standard. Wehave done tests with the implementation of reducedvertical separation, which was not of the samestandard but it can be used as a comparison. We havedone some tests as to what the impact would be ofaircraft not being able to fly in an RVSM area. Inother words, they would require the old separation.The findings were that, if more than 2% of the traYcdid not have the RVSM capability, all of the benefitsof all the aircraft would be completely wasted. If wemove to such an environment, therefore, we have tobe able to do it for all aircraft. Having said that, therewill be adequate mitigation. For instance, formilitary aircraft it is sometimes very diYcult,because of the very limited size of the cockpit infighter aircraft and the weight of the equipment. Forgeneral aviation it is the same issue: they cannot havelarge equipment; they cannot carry the weight and,for general aviation, there is also a costconsideration of course. They still need to beaccommodated. Even though we are trying toimplement new rules for advanced navigationcapability and its application, we always keep inmind that there are certain communities, like themilitary and the general aviation community, thatmust still be accommodated, and provisions arebeing made for that in consultation with all of thestakeholders, including NATS.

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Q317 Mr Leech: Should governments or aviationregulators across the EU be able to insist on aircraftor airlines using the most up-to-date equipment?Mr Hendriks: The answer would be yes, but it is notso much of an issue. I mentioned earlier that theairborne capability is very often light years ahead ofthe ground-based ATC system; so many of theaircraft already carry the equipment today. TheAirbuses and the Boeings that are being deliveredtoday already have that capability.

Q318 Mr Leech: What proportion of aircraft in theskies currently has the most up-to-date navigationequipment?Mr Hendriks: I do not have the exact figures, but itwould be in the order of 75 to 80% already today.

Q319 Sir Peter Soulsby: Following on from that, Iwant to explore further how and at what stage it isintended to enforce the requirement to have the mostsophisticated equipment to enable the full benefits ofthis to be achieved. When and how will it happen?Mr Calleja-Crespo: I think that it is very importantfor us to explain the approach of the SESARprogramme. There is a definition phase, which hasbeen concluded and, next week, we hope to completethe membership agreements leading to the accessionto the SESAR Joint Undertaking, which will be theinstrument that will be in charge of the developmentphase. We have the European Commission, which isputting in ƒ700 million over the next seven years;Eurocontrol, which will put a similar figure; andthen we have 15 very important players from Europeand also from non-European Member States. Wehave the air navigation service providers, we have avery important contribution from NATS, and wehave from other countries—from Spain, fromGermany, from Italy—air manufacturing. Basically,the key players are putting in the money andassuming the risks of this very importantprogramme, and then we will have the deploymentphase, and I think you were right to mention thechallenges of the deployment phase. How is thisgoing to work and why is industry so committed toSESAR? It is very complex and it is a project whichinvolves risk. I think one of the important elements,or one of the advantages, that SESAR will have, isthat, first of all, we are pulling the resources ofresearch, which were being distributed in manydiVerent directions, towards a big project based onthe gate-to-gate approach, which is going to bringhuge benefits to the aviation system. Second, wehave the main players involved. Third, this projectwill be intra-operable. We have an agreement withthe United States to ensure that SESAR and theNext Gen system, which is a similar programmewhich is being done by the United States, will beintra-operable, so it will be a global system. Thenthere is the last element (and I come to yourquestion), there is something which we can producewhich makes it extremely interesting. It is not just aresearch project; it is not just the results of theresearch; we can actually standardise the results ofthis research in a very eYcient way as soon as theresearch is developed, as soon as we have concrete

results. Through the Single European SkyCommittee, where we have all the Member States ofthe European Union, we can take decisions on dataoperability, we can set the standards and we can havethis technology standardised, certified and fullyoperational. When? As far and as long as theprogramme is continuous, it produces itsdevelopment. There are a certain number of workpackages. We will have to see the results. We hopethat we can have some low-hanging fruit, somequick deliveries, because it is important when youare thinking of such an amount of money that thereare important concrete developments—I think ourcolleagues maybe can provide more details—andthen we can very eYciently, at European level,standardise this technology. Once this technology isstandardised we have agreed with the countries, forexample, the United States,—and yesterday we hada very important meeting in Amsterdam betweenSESAR and Next Gen—that we will work togetherto ensure intra-operability and we will go together toICAO to have a International Civil AviationOrganisation certified. What we are building is aglobal system. SESAR is an open programme andwe are interested in having third countriesparticipate, third countries which have aviationagreements with the European Union on the basis ofreciprocity, because we want also our industry tobenefit from similar opportunities which they maybe launching right now. On these conditions we areready to do it, but it is the standardisation which isextremely important. This technology can becertified and implemented as a European standard,and this will allow it to be used and operated withinthe EU. This is also one of the added values whichthe European Union can bring to these kinds ofprogrammes.

Q320 Sir Peter Soulsby: In brief, there will come apoint where you will say, “If you do not have this kit,you do not operate”?Mr Calleja-Crespo: I do not know. I ask mycolleagues.

Q321 Chairman: Who is going to give the verdict onthat one? Mr Hendriks.Mr Hendriks: We have always, so far, in theprogrammes where we have introducedrequirements for aircraft followed the line that, if inthe end you do not have it, you no longer fly, but thishas always been in very close concert with theAirspace Users Organisation, giving them adequatelead-time in order to equip the aircraft, withadequate mitigation for those who are unable toequip. To give you an example, when basic RNAVwas made mandatory, IATA, very close to theimplementation date (IATA is the International AirTransport Association—the association of all theairlines), convinced us to postpone because theywere not ready, their members were not ready, so wepostponed the implementation for a couple ofmonths, and then we all agreed on a commonimplementation date. Just days prior to that

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implementation, one or two airlines said, “I amsorry, we still have one or two aircraft unable tooperate and we have a schedule to meet. Could wehave an exemption?” In consultation with all thestates and the service providers, exemptions wereissued lasting three months, and that gave thoseairlines adequate time to retrofit the aircraft. It is aflexible approach, nobody should be penalised, butwe should certainly also not penalise those airlinesthat have invested in accordance with the plan tooperate aircraft.

Q322 Chairman: In your earlier evidence, as Iunderstood it, you were saying that either everybodyhas it or, eVectively, it cannot operate. You cannotaVord even a small percentage opting out.Mr Hendriks: It is not eYcient if not all of themhave it.Mr Calleja-Crespo: I would to also introduce acaveat in this discussion. Obviously, aviation isglobal, there are global standards and we have tocomply also with ICAO. We have examples where atworld level, being the International Civil AviationOrganisation, for example, for safety reasons, wehave forbidden access to Europe, after a certaintransition period, aircraft which were not equippedwith certain safety elements. This has always beendone in the framework of the ICAO, because we arespeaking about the global sector and we have anInternational Civil Aviation Organisation. Wewould have discussions with third countries inthese matters.

Q323 Sammy Wilson: Can I come back to the lastanswer you gave to Mr Wilshire, because I am a littleconfused about the level of intervention that therewould be with the Network Management Functionwith either CAA or NATS. You said that as far asthe current situation was concerned you would notbe able to intervene to overrule, so that there wouldbe national sovereign responsibility.Mr Calleja-Crespo: Yes.

Q324 Sammy Wilson: And yet, in the writteninformation that you gave, you have indicated that,first of all, in order to get a European system in place,Eurocontrol said aerospace planning, design,management and the prerequisite processes cancurrently hardly be considered as a nationalsovereign responsibility, so there are elements therewhere you are saying that you will wish to overruleinveigled nations because this needs to be addressedin a pan-European context, perhaps facilitated by acivil entity such as Eurocontrol. What elements ofnational sovereignty do you see being removed inorder to achieve the kind of uniformity that isreferred to here?Mr Calleja-Crespo: I think that what we are tryingto do is to enhance the performance of the Air TraYcManagement System. There could have been anapproach which could have been followed, which isan approach I call personally the “big bang”. Bydecree we establish in Brussels the Single European

Sky. From tomorrow national sovereignty overairspace ceases, it is centralised by Brussels, and werun the whole show: all the national sovereignty istransferred into Brussels. This is not the approach.The approach which was agreed by the MemberStates in 2004 is a bottom-up approach. Countrieswork together, they try to have a more eYcient AirTraYc Management System, they put in place thefunctional airspace blocks and they try to improvethe performance. What does the Single EuropeanSky II add to this approach? It adds two importantthings. First of all, it introduces dates. We are askingcountries to establish the functional airspace blocksby 2012, because we believe that if there is not somedate, there will be many discussions but progress willbe uneven. Some countries have started before—theUK and Ireland were the first—but others are notmoving fast enough to improve the performance ofthe system. Second, we introduce a performancesystem in which we allow the EuropeanCommission, on the basis of the input from thenational authorities, to adopt targets, targets whichwill deal with a certain number of importantconcepts like flight eYciency, like environment, likesafety, and this will be implemented at national level.The element of targets is extremely important.Fourth, we have this as our programme, we have theextension of competence of the system, and then wehave a function, which is a supporting function,which is the network management. The networkmanagement is not there to overrule anyone; it isthere to support the co-ordination between theMember States; it is there to provide some support.It cannot have binding powers in the countries, butit can usefully help to co-ordinate, to manage betterthe frequencies, to give guidance also on how thefacts should work together better. However, thenetwork management function is not a legallybinding function, it is a support function, so it wouldbe wrong to assess Single European Sky only on thebasis of this element. This element is part of thewhole picture where you have the performance-based system, where you have the extension toEASA, where you have SESAR and where you havealso dates for the establishment of FABs.

Q325 Sammy Wilson: If you are, first of all, sayingthat there has got to be a uniform design because theparts have got to fit in, and then you are talkingabout a gate-to-gate management so that you havethe most eYcient route, et cetera, not only are yousaying that you can interfere if the design is not right,you are also saying that the operation of that design,once it is up and since you want to monitor aircraftand get them to ensure that there are eYcient routes,et cetera, used, also involves you interfering at anoperational level.Mr Calleja-Crespo: No, what we think is that thiswhole system will evolve logically and naturally to amore eYcient system, because the FABs willintroduce more benefits, because the networkmanagement, as the countries discuss the variouspossibilities, will also seek some approximation,

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because the performance targets will also play a rolein the system and because SESAR will provide thetechnology, so I do not think that “interfere” is theright word. On the contrary, I think all the elementswill lead to a more eYcient functioning of thenetwork as a whole, not through interference ordirect action but by all the elements workingtogether. The key word behind the Single EuropeanSky process is “partnership”—partnership with theMember States, partnership with industry, nationalsupervisory authorities, air navigation serviceproviders working together to improve theperformance of the system.

Q326 Sammy Wilson: So if a company decided that,yes, there is the ideal design that your controller orthe network management function would like, butthey want to have a diVerent design, you would notinterfere in that, or, if, once it was up and running,they decided, for whatever reason, they want to havea variation, you would not interfere then?Mr Calleja-Crespo: As we would say in Spanish, youwant to be more Pope-ist than the Pope. No, wewould not be able to interfere. We act on the basis ofthe powers which Member States confer upon us,and Member States do not want us to go that far.

Q327 Chairman: I think it is a question; it was not astatement of the position.Mr Calleja-Crespo: What I mean to say is that theEuropean Commission does not have powers tooverrule Member States in their sovereignty. There issomething very important in Single European Sky towhich I would like to draw your attention, which iswhat we call the safeguard clause. We have asafeguard clause, which says that the whole exerciseis done to try to work together to improve theperformance of the system but that in no case can wetouch on very sensitive issues—military issues,defence considerations, national security. If theCommission had this power to say, “Now you arenot allowed to do this”, we would be interfering, asyou say, with these systems. I think that is not theapproach. That approach would be that from dayone we establish the Single European Sky. Theapproach is the bottom-up approach. It is countriesworking together that make the system work and weare introducing some elements to accelerate theprogress, to make it more consistent, to have somedates, to have the performance system, to havesupport network management functions, but we rely,at the end of the day, on the initiatives that comefrom the countries. The FABs do not come from theEuropean Commission; the European Commissionhas no power to establish an FAB.

Q328 Sammy Wilson: If you find then that, forwhatever reason, some countries decide that they donot wish to go down the route of this kind of unifieddesign, or whatever, that there will be a notice in thebrief that the ultimate responsibility is yet to bedetermined for the network management function(or whatever body is set up) over the next number ofyears, do you not see those powers and

responsibilities, which have not yet been determined,becoming greater so that there is that greatercentralisation?Mr Calleja-Crespo: If countries do not agree to go inthis direction, because what we are presenting to thiscommittee is proposals from the Commission whichare under discussion, they will not go forward. Ifcountries agree to go in this direction, then we willsee how the process evolves, but at this stage theseare proposals under discussion. If a country hasdiYculties in accepting this, then they will opposethis situation.

Q329 Sammy Wilson: So more responsibilities tohave a greater level of interference could be taken onin the future?Mr Calleja-Crespo: I did not understand.

Q330 Sammy Wilson: Since the full responsibilitieshave not yet been determined, if it was found that,for whatever reason, the bigger countries decidedthat they wanted to have their own national imprinton whatever systems were designed, additionalresponsibilities could be taken on at this point, couldthey, to allow for that level of interference?Mr Calleja-Crespo: I would have to check that. Wehave a provision, I think. Countries, if they are notconvinced, could leave.

Q331 Chairman: If there is further information onthat, perhaps you could send it to us.Mr Calleja-Crespo: Yes. We can provide thisinformation.Mr Wilshire: Can I say one thing, Chairman? I havebeen listening to this question of which direction weare going in. It leaves me with a view that a pilot callsup Eurocontrol and says, “Do you want me to turnleft or do you want me to turn right?”, and theanswer he gets is, “I will talk to five committees, 27countries, think about it and in due course I will letyou know.” That is no way to make progress with airtraYc control.

Q332 Chairman: Whether that is the situation is notclear. I do not know who would want to answer anyof that.Mr Calleja-Crespo: I do not know what Eurocontrolhas to reply, but if the Member States want to gofurther and confer more sovereignty on Brussels togive us this power, it is always a possibility, but thisis not the state of play right now.

Q333 Chairman: Mr Hendriks.Mr Hendriks: Just to step in there, Eurocontrol canonly act to the extent that our Member States haveempowered the agency to do so, not beyond that,and it is the same with the European Commission.The European Commission has received a certaincompetency and can operate within thatcompetency. If states decide to extend thatcompetency, then so be it, but we have to workwithin the competencies given to our respectiveorganisations. The network manager is, to a largeextent, a focal point, a facilitator, a co-ordinator to

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ensure that we get a pan-European network that canonly operate within the competency given. I thinkthat is the answer.

Q334 Chairman: Thank you. We have kept you along time, a lot longer than we had planned. Perhapsthat indicates the amount of interest, but I think weshould let you go. You perhaps have trains to catch.

Witnesses: Mr Ian Hall, Director of Operations, Mr Alex Bristol, General Manager Operational Strategyand Investment, and Mr Lee Boulton, Manager Airspace Delivery, NATS, gave evidence.

Q335 Chairman: Good afternoon, gentlemen. I amsorry for keeping you waiting. I think you heardsome of the previous session. We did have a lot ofquestions and we had some full answers too. Could Iask you to identify yourselves, please, for the record?Mr Hall: Certainly. My name is Ian Hall and I amOperations Director of NATS.Mr Bristol: My name is Alex Bristol; I am theGeneral Manager, Operational Strategy andInvestment for NATS.Mr Boulton: Lee Boulton, Manager AirspaceDelivery within NATS.

Q336 Chairman: Thank you very much. What willbe the impact of the proposed additional runways insouth-east England on airspace?Mr Hall: The decision to proceed with runway threehad to be anticipated, to some extent, in order for usto think to the future about what kind of airspacedesign the London area was going to need in the longterm and, of course, we had several scenarios that wehad to work through. The decision to go ahead withrunway three means that at least one piece of thejigsaw becomes clearer. The next stage for us is todevelop the specific airspace design and address thespecial issues to do with the additional routes thatneed to be established, the kind of navigationperformance and equipage that it is going to benecessary to operate, and then we need to establishwhat the priorities are for the use of the runways andwhat the priorities would be in terms of thedistribution of the traYc according toenvironmental issues. There is a lot of work that wehave to do, but, I have to say, I think we welcome theadditional piece of clarity that one bit of strategicdecision is put in place.

Q337 Chairman: When do you expect the work to becompleted?Mr Hall: Much of that depends on the processes forthe planning, for the approval, for the completion ofthe runway itself and decisions that need to be madearound the use and the infrastructure on the ground.Until we have got clarity about that, we will not startto develop specific airspace change proposals.

Q338 Ms Smith: I wanted to ask why you feel thatan airport in the Thames Estuary would not befeasible in airspace terms?

Thank you very much indeed for coming and foranswering all our questions so fully. We doappreciate you coming here to see us.Mr Calleja-Crespo: Thank you very much. For us Ithink it was a very pleasant experience, and I did notexpect to have such strong appeals to do more at aEuropean level in this area. Thank you very much.Mr Wilshire: Just remember which country you arein!

Mr Hall: NATS’ view has been quite consistent that,in terms of the overall eYciency of the air traYcmanagement system, the operation of aviation in theair generally around London, it is better to expandthe existing infrastructure than to create newinfrastructure, and that can be illustrated fairlysimply by the experience that we will all have here onseeing the aircraft flying into Heathrow over thisarea. If there were to be an airport in the ThamesEstuary, then aircraft would be taking oV from thatdirection, much as they do at London City, but inmuch greater numbers, and the integration of thosearrival routes and departure routes would justincrease the complexity of the overall system, so itwould either be a question of replacing existinginfrastructure, or expanding the existinginfrastructure, rather than creating newinfrastructure to operate alongside the others.

Q339 Ms Smith: Moving on to something slightlydiVerent, NATS is concerned about a lack of rigourand clarity in determining the appropriate balancebetween emissions and noise. Who do you thinkshould take the lead in addressing this issue?Mr Hall: We are pleased now—this is a consequenceof the Pilling inquiry—that extra powers are going tobe given to the Civil Aviation Authority to provideguidelines and oversee the balance of environmentalissues alongside airspace issues, so it is veryspecifically for us, it is not something that we cantake on, but we look for a policy decision to help usand, of course, the clear challenge is between thepressing need to limit the climate change eVectsversus other environmental issues such asdistribution of noise, or visual intrusion, orwhatever. It is that balance that we are really lookingfor further guidance on.

Q340 Ms Smith: When you say “a policy decision”,you really see the responsibility for that lying withDfT perhaps?Mr Hall: My personal view is that I do not think(and I think this is NATS’ view as well) that there isa clear policy that one should apply and the othershould not. There is always going to be some degreeof balance, depending on exactly where the route isand what the consequences are going to be, but ifthere were to be a clearer policy, or, as we werecreating our strategies we were able to determine ina more coherent way how to put these policies orparties together, then it would make it much easier

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to create a more consistent strategy, let us say, forairspace development, and then everyone wouldhave the relief of at least knowing what the long-term view was. At the moment it is very hard foranybody to establish a long-term view.

Q341 Ms Smith: So we are looking at a policyframework, really, which would be DfT?Mr Hall: Yes.

Q342 Ms Smith: Have any wrong decisions beenmade so far as a result of the problems around thebalance between emissions and noise? Have anywrong decisions been made so far because of thedelicate balance between emissions and noise, wouldyou say?Mr Hall: That is a very diYcult one to answer. Havewe had to make subsequent adjustments? I wouldsay, yes, we have, but in this instance ahead of thefinal decision. When we consulted on thearrangements for TC North, as it is known, theairspace to the north and east of London, it was agenuine consultation exercise based on the bestinformation that we had, and we put a proposalforward which we thought would establish the bestoverall compromise in terms of those sorts of parties.The widespread consultation meant that we had a lotto review when we got all of that information clear,and that has resulted in us reconsidering thosearrangements and we will have to go out toconsultation on that again, but in terms of the pointmade about any wrong decisions and the wish toavoid them, this is a learning exercise and in manycases these environmental trade-oVs are verysubjective and so opinion counts a lot in trying todecide the final outcome.

Q343 Ms Smith: Finally, just to change topicsslightly again, to what extent do you think theproposed network management function willchange aerospace design responsibilities, bearing inmind the witnesses’ evidence given earlier as well?Mr Hall: I think the starting point for answering thatis to reflect on the complexity of air traYcmanagement itself, the complexity of the airspacesystem and the need to get a lot of alignment aroundinvestments, particularly in aircraft equipage, butalso in the infrastructure on the ground. That meansthat having a strategic plan behind which everyonecan align their investments is absolutely crucial, andso we welcome the Single European Sky framework,we welcome SESAR, the research aspect of that; weare heavily involved in that and directly committedto it. We also support the notion of a level of co-ordination between these functional airspace blocks.Having been the first to get one established and thenwith another even bigger one right on our doorstep,it is really clear, as I said earlier, that the trianglebetween Amsterdam, Paris and Heathrow is crucialto all of that, but it does need somebody who is notin one of those two groups to help co-ordinate all ofthose activities. Quite how much power they mighthave remains to be seen, and I think that wasprobably reflected in the fact that that has not finallybeen resolved yet. At the moment our general

approach seems to be to build constructively andpositively and to have someone who can brokerthese sorts of arrangements, but that will need somesort of rule-making process to enforce it.

Q344 Ms Smith: Finally, can I ask you to takeabsolutely what you have just said to indicate whatyou think the powers of the co-ordinating functionmight be or should appropriately be? By that I meanif you feel able to answer as fully as possible.Mr Hall: What I can do is say that the need for rulesin air traYc control is pretty obvious. There have tobe some clear rules, and that includes the way inwhich aircraft must be operated and whatequipment they must carry. They also apply to us interms of the distances that we have to separateaircraft and the methods by which we transfer theaircraft, or transfer the information about aircraft.There are clear rules around that, so we are quiteused to operating in a rule-making framework. Thefirst round of Single European Sky bottom-up wasvery gentle and suggested, for example, thatfunctional airspace blocks ought to be created byaround 2010. It was quite vague, quite impreciseabout what had to be delivered. When it wasapparent that there was not suYcient momentum,the rule-making was tightened up, and under theSESII there is now an implementing rule that saysyou must implement by 2012, and that is a rule madeby the states through the EU and the Commission tobe applied by the states, so for me that frameworkfor rule-making is suYcient at the moment. There issuYcient will to comply with that kind of frameworkfor ruling for me not to be concerned that we wouldcome into conflict, for example, with the networkmanager or the nature of rule-making, because therewill not be a firm rule until there is a unanimous viewacross Europe that the rule is justified.

Q345 Ms Smith: They seem to have got the idea thatday-to-day management of air traYc may becompromised, perhaps, by having this networkmanagement function at Eurocontrol. Can youreassure us that day-to-day management anddecisions made in a particular airspace block will beleft to the national air traYc control system?Mr Bristol: I think the answer to that is just areference. What happens today? We have an airtraYc central flow management unit in Brussels,which has a co-ordinating function centrally acrossthe network within Europe. Each individual statewill then stick within its own guidelines, within itsown rules, and will continue to assure safety andmaximise capacity within the context of safety intheir own airspace. I do not see that changing.

Q346 Chairman: So you do not have any concernson this issue?Mr Hall: To say we do not have any concerns wouldbe going too far, because the final arrangements havenot been concluded. I think Eurocontrol have beeninvited to make proposals now for the way in whichnetwork management is handled. What we aresaying is that the rule-making framework, we think,

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gives us confidence that it is highly unlikely wewould end up in a conflict where we were forced todo something that we did not think was appropriate.

Q347 Mr Wilshire: I have got three areas I would liketo explore briefly with you, but before I do can Iexplain that I have another meeting to go to andwhen I walk out it will not be in disgust at yourevidence. I apologise for that before I start. Can Istart with safety? You were nicely installed in thestalls, listening to the previous performance, and youheard, first of all, a compliment that you are amongstthe best in the world at the job that you do, and thenit was suggested that, because you are, you wouldbecome complacent. Do you have any sense ofcomplacency?Mr Hall: No.

Q348 Chairman: You could not say yes to that!Mr Hall: There is absolutely no way could I say yesto that. I have got an emotional answer to that andI have got a technical answer too. The emotionalanswer is that I think it is quite diYcult for anyonewho is not involved in air traYc control tounderstand the personal connection that peoplehave to the subject of safety. We are totally,constantly abhorrent of the risk of aircraft gettingclose together and, of course, worse, there being acollision. It is something we live with day in, day out,so the notion of complacency is anathema to us. Thesecond thing is that we absolutely understand andmaintain that safety is our top priority and becauseof that every business case that we look at includesan analysis of the safety benefits which come with it.Not only that, we have inside NATS just revised ourstrategic plan for safety and committed andidentified precise resources to be applied, not only tomaintain safety, but to take safety to whole newstandards, and so, despite the fact that it is good tohear that our practices are celebrated and taken onby other people, we are relentless in our pursuit offinding further ways to improve safety.

Q349 Mr Wilshire: Do you have any sense at all, inthe developments that are taking place in Europe,that there is even the slightest risk that yourstandards will be compromised?Mr Hall: It is very diYcult to imagine any way thatthat could happen, and the reasons are the safetymanagement systems that we have got, but also theconfidence that we have in the regulator that we havein the Civil Aviation Authority, which is alsocommitted to ensuring that UK standards are notdiluted through the establishment of standards atEuropean level and, in particular, EASA. I shouldalso say, if it was not clear from the arrangementsunder the Single European Sky, that standards at aEuropean level must be applied at a state level, andit is the state level that gets to determine if it wantsany additional measures put in place over and abovethe European standard. Everything that I have seenso far points towards, not a dilution in UK airspaceas a consequence, but relentless pursuit ofstrengthening that, and I am quite confident thatthat will be maintained.

Q350 Mr Wilshire: Do you feel able to give thiscommittee an undertaking that, were you to changethat view and were you to become concerned aboutthe possibility of a dilution of standards, you wouldbring that to our attention?Mr Hall: I think that it would very quickly come toattention. The processes that we have for monitoringour eVectiveness are public and taken right to thehighest level in terms of NATS itself, but also themonitoring that we have through the CAA ensuresthat there is complete transparency in terms of oursafety management and safety organisation. It iscommon for the CAA’s inspectors to be present inour operations rooms on a day-to-day basis,confirming for themselves that we are sticking to thestandards and that there is authenticity to theperformance reports that we produce.

Q351 Mr Wilshire: I appreciate that, but the specificthing that I asked was would you be able to give usan undertaking that you would draw it to ourattention? I understand that it may well becomeclear, but that was not quite the same thing as Iasked you.Mr Hall: I am not quire sure, in a really specific way,how to answer that question. Are you asking wouldwe constitutionally, in a sense, by-pass all theprocesses, and come to this committee? Is that thequestion?

Q352 Mr Wilshire: I am not necessarily asking thatyou by-pass. I might be suggesting that you copyus in.Mr Hall: I can certainly take that away. I do notknow constitutionally how to commit to doing that,but I am sure we do not have a problem with it.

Q353 Mr Wilshire: Can I make the suggestion thatyou do take it away, you reflect on it, you ask thosepeople I am sure you do need to ask and then writeto us saying what your conclusion is?Mr Hall: With pleasure.

Q354 Mr Wilshire: That would be helpful. Could Imove on, Chairman, to the use of runways for amoment. What do you consider to be optimum usein percentage terms of a runway?Mr Hall: What we can say is that a high-performingrunway, under good conditions (and I would useseveral of the airports in the London area asexamples) can operate to very, very high levels ofutilisation, and I think the documentation indicatesthat Heathrow operates at 98%. I think thatprobably reflects some degree of averaging, becausethe declared capacity for some of these airports isregularly exceeded by the numbers of flights thatturn up, and that is what leads to the queuing—thequeuing on the ground and the queuing in the air.Therefore, part of the utilisation of runways whichneeds to be considered, and, in particular, of course,as a consequence of the announcement on runwaythree, is the extent to which runway utilisationshould be reduced from its maximum theoreticalcapacity in order to provide greater resilience andallow for the shift that happens in schedules because

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of the vagaries of air travel but also because of theeVects of the weather. That is one of the issues interms of a framework of policies that might behelpful when it comes to establishing the realairspace design.

Q355 Mr Wilshire: Can I take that answer as beingan indication that trying to use a runway at 98%,which is what Heathrow tries to do, is probably nota good idea on the basis of fog, thunderstorms andother things?Mr Hall: What I am saying is that it is an inevitabletrade-oV and it is not one that NATS can make thecall on. What we can do is provide the infrastructureto support whichever decision, in terms of priorities,there is general consensus around. At the momentwe are living with the consensus view that queuing inthe air and queuing on the ground is worth it in termsof the benefits of the high levels of runwayutilisation, amongst the highest runway utilisationin the world, right in the middle of the most complexairspace in the world.

Q356 Mr Wilshire: So you are accepting that there isa link between queuing on the ground and stackingand high use of a runway?Mr Hall: Yes, I am.

Q357 Mr Wilshire: Therefore, in order to reach someof the environmental objectives, it would be sensibleto use the two existing runways less than they areused at the moment?Mr Hall: Yes, I think, as we stand at the moment,that is an obvious trade-oV that we have got. Wehave got queuing. We could reduce the queuing if wereduced or used the increased capacity, for example,for runway three to first reduce the queues and thenincrease the utilisation. The issue about fog and highwinds, and so forth, is another decision, again,because it happens very infrequently and therewould be a clear waste of capacity if we were toassume every day was a foggy day.

Q358 Mr Wilshire: Is it a coincidence or is theremore to it? Frankfurt, Schiphol and De Gaulle seemto think that 75% usage is about as high as youshould go.Mr Hall: It is very diYcult to make these straightcomparisons. The procedures that we operate to inconfined airspace are practised to levels that theseother airfields cannot quite support. That is oneaspect. The other aspect is they have got many morerunways and they have got massive airfieldinfrastructure. We had the pleasure of being inAmsterdam yesterday, where, after you have landed,you are taxi-ing for 15 or 20 minutes to get anywhereclose to the terminal building. It is the same at Paris.It is much less at Heathrow after you arrive, becauseit is much more compact, so the pressure is not onthem to achieve the levels of utilisation that we areattempting to achieve in our airspace.

Q359 Mr Wilshire: The third thing, Chairman, isairport development. You make the general pointthat the cost of doing a great deal of detailed work

in advance of some firm proposals is probablyexcessive cost, and yet, if a project is not going to beviable from an air traYc control or a safety reason,would it not be better to know that earlier becauseof the other costs, that would be abortive costs?Have you any solution as to how you might find away of meeting those costs or expecting other peopleto help you meet them so that you can start workearlier?Mr Hall: In terms of the arrangements, if we were tounderstand, for example, that the clear priority wasto limit the climate change impact of additionalflights, then we would be saying we could puttogether a structure that did that but it would notreflect the trade-oVs for other environmentalimpacts such as noise, visual intrusion, and I knowthe sensitive issue of alternation at Heathrow has animpact on the routes and has an impact onutilisation. These are other sensitivities that it isimpossible for us to model in until some view istaken about the extent to which those trade-oVsmust apply, and what we are looking for through thework that we are doing with the CAA and the DfTon the future airspace strategy is to try to establishwhere these key issues are likely to appear and tostart to take a view about the likely scenarios againstwhich we can produce our long-term plans as part ofthe process that we are trying to put in place at themoment.Mr Bristol: May I add to that? To give an exampleof the Heathrow third runway, we have not done nowork at all on this. The initial part of work was doneto have a look at whether it is, indeed, feasible. Wewould then see if there are show-stoppers. If thereare, we would then make those clear. It is not quiteas cut and dried as not doing any work at all until athird runway is announced; there was somefeasibility work done previously.

Q360 Mr Wilshire: Are there any show-stoppers?Mr Bristol: No.

Q361 Mr Wilshire: Could I ask you about a diVerentsort of show-stopper? I understand that it is yourview that if Boris Island were to be built the only wayin air traYc control terms that it could be operatedwith flights coming out from the west or going infrom the west would be the closure of Stansted,Heathrow and City Airport. Is my understanding ofyour position correct?Mr Hall: I would not go quite as far as that. WhatI was trying to do was illustrate that, by adding anadditional piece of infrastructure into that verycomplex mix, it would have a very direct impact onthe overall capacity of the London area. In otherwords, you would get a much better increase incapacity by expanding existing infrastructure thanyou would if you built that infrastructure somewhereelse after that.

Q362 Mr Wilshire: In order to use a new airport builtin the Thames Estuary you would have at least tocurtail the use of Stansted, Heathrow and City. I

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have heard you explaining this. Is it minorcurtailment, is it complete closure, or is it somethingin between?Mr Hall: It really is a matter of trade-oV at the endof the day, but it is our responsibility to make it clearthat, from our point of view, if you were to addadditional infrastructure such as that you should notexpect to get the full benefits and you certainlyshould not expect to get the same benefits as if youexpanded existing infrastructure. I should also saythat we have not done the detailed work on that. Wehave not seen any specific proposals, for example.Informally we have been putting in some inquiries toestablish what the likelihood is, but it goes back tomy previous point (and I understand your point aswell about chicken and egg here). We can go so farin saying it is diYcult to see how you would really getthe benefits. On the other hand, until somebodycomes up with some proposal, we cannot do anydetailed work on modelling to find out what mightbe possible.

Q363 Chairman: That sounds, Mr Hall, as ifsomebody has suggested you modify your views.Would that be right?Mr Hall: I am sorry?

Q364 Chairman: Your recent statement suggests thatsomebody has suggested you should modify yourearlier views on the impact of the possible newairport. Is that right?Mr Hall: No, I think we have been consistent all theway from our contribution to the 2003 White Paperabout the general approach to adding capacity in theLondon area. I also think that we have beenconsistent in our view that it is much better toexpand existing infrastructure than it would be tocreate new infrastructure.

Q365 Mr Wilshire: It is a slightly less firmexplanation you have given this afternoon than wewere given when we visited Swanwick, where wewere told that it would involve the closure ofHeathrow, Stansted and City Airport.Mr Hall: I am sorry if it appears to contradict that.Certainly there has not been any subsequentconversation or clarity of policy on this point. Iremember the discussion that we had at Swanwick,and we stood in front of a map to try and illustratethe point, and I am sorry if the language came acrossin a more, how can I say, precise way than wasintended. What we were trying to do was indicate theproblem that was created by trying to do it ratherthan to say that one or all of them would have toclose as a consequence. I remember saying that if youput an airport here and an airport here and thedepartures from this airport were flying straighttowards the flights that were arriving for the otherairport, then something would have to give, andright at the moment we do not see how those twoairports could operate at full capacity at the sametime. It is as simple as that.

Q366 Chairman: Has somebody suggested to youthat you should change your position?

Mr Hall: No, they have not.

Q367 Chairman: You are quite sure. It has not beensuggested to you it might be better if you had a lessfirm view?Mr Hall: I have not spoken to anybody on thesubject, since we spoke at Swanwick, until thequestion was asked here.

Q368 Mr Wilshire: Let me see if I can have one lastgo at clarifying this, at least in my mind if nobodyelse’s. If a four-runway or a three-runway airportwere to be built in the Thames Estuary it would notbe possible to use that airport at its full capacitywithout reducing the use of Stansted, Heathrow andCity Airports?Mr Hall: That is our view, yes.Mr Wilshire: A compromise then. Thank you forthat.

Q369 Chairman: Do commercial interests have thepower to overrule any view you may have on the bestuse of airspace around airports?Mr Hall: The processes for deciding on our owncommercial interests within NATS in terms of whatwe invest in are a direct consequence of theconsultation processes that we follow and thepriorities that are set for us by the DfT, by the CAAand by the customers themselves. We are hugelysensitive to the diversity of the airspace users thatrequire access to our airspace, and we are also verysensitive to the issues on the ground. It is because ofthat sensitivity that we will invest in systems that donot appear to have any commercial value for uswhatsoever but are of benefit to our customers. Ourcommercial arrangements and the returns that weexpect to get on any of our own investments, whichis the source of our income; in other words, our owncommercial interest is in satisfying the customersand the infrastructure around us. What that meansis that we consult extensively with our customers onall of our capital investment plans, and we arecapped in terms of the capital expenditure we areallowed to use. Despite that, we still will reflect it incustomer need as a baseline for making ourcommercial decisions.

Q370 Mr Leech: NATS has said that it is vital towork with the CAA, to be proactive in developingnew technologies and techniques and, to quote you,“where necessary, mandating equipment to ensureconsistency of application”. Has the CAA failed tobe suYciently proactive in mandating valuabletechnologies and techniques?Mr Hall: The rule-making processes requireconsultation, and there is one specific example ofpotential rule-making which had been notified,which is the mandatory carriage of transponders.This is a piece of radio equipment on an aircraft thathas the ability to transmit to air traYc control and toother aircraft their identification and the height thatthey are flying. It can also go on and give air traYccontrol additional information which is helpful.When the consultation process was followed,against a clear indication of an intention to

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implement this rule, for which we were gearing ourinvestments, the response to the consultation put theCAA oV proceeding with that rule-making and nowcarriage of transponders is not anticipated until2012. This, for me, is an example of what happens ifthe rule-making process that we discussed earlier,even at a European level, breaks down; that you findone part of the infrastructure is geared up to assumethe benefits of rule-making, particularly onequipage, and then it does not happen and you havegot some costs but no benefits, and we ended up inthis instance having to invest more money to makethe airspace safer until we can get to transpondercarriage.

Q371 Mr Leech: So it is fair to say that the CAAhave failed to be suYciently proactive?Mr Hall: I do not want to give the impression of ajudgment on the CAA itself, but what I do want todo is reflect on the process which the CAA is obligedto go through and demonstrate that the consequenceof following it in the way it did resulted in the non-implementation of a rule that was going to be very,very valuable for UK airspace, and I want to pointto the need for us to learn the lessons from that andmake sure that the subsequent rules that need to beput in place are put in place much more firmly. Thatis why I think, both through the framework of SingleEuropean Sky and by having a clearer policyframework for the implementation of these rules, theDfT can support the rule-making and build upgreater momentum for the CAA to ensure that therule-making really does come into force.

Q372 Mr Leech: So what else needs to be done nowrather than waiting for the future?Mr Hall: The sorts of equipment that we want toimplement in the near future will depend on rule-making. The transponder carriage in 2012 is anabsolute must. The rule-making to support thedevelopment of the precision navigation systemsthat were being discussed will also have to beimplemented in those sorts of timescales. There isalready a rule for us to implement data linkcapabilities so, instead of controllers speaking topilots, they can send messages straight on to theflight deck, and that rule is due to be implemented in2013. We would like to see further rule-makingbehind that to ensure that the benefits achieved bythe technology can be accelerated and broughtforward. At the moment it is diYcult to see how toget those rules put in place. I am trying to illustratethe point—I appreciate the question—of beingfocused on what are the clear rules that will reallymove the game forward and produce benefitsquickly and then getting everybody committed andthe industry committed to delivering them.

Q373 Mr Leech: British Airways have said that“airlines would already use these techniques if theywere not constrained by UK and European air traYccontrol practices which we believe can be made moreflexible”. Would you agree with that assessment?

Mr Hall: I cannot be sure exactly what systems theywere talking about, so it would be diYcult for me torespond to that in context. SuYce it to say thatBritish Airways, amongst many other airlines, havea very modern fleet which is very well equipped andcould operate in more advanced ways, and if we wereable to ensure that the whole aviation fleet wasestablished to the same levels, then, yes, there aremore things that we would be able to implement.

Q374 Mr Leech: Is there an argument for airportsbeing able to restrict the use of aeroplanes that havegot the most up-to-date technology?Mr Hall: I think in any of the systems that you wantto optimise, if it requires the benefits to be achievedby everyone meeting the same level of capability,then, yes, it is justified, and I say that from theperspective of the whole nature of air traYc controlbeing around the fact that it relies on people beingequipped to the relevant standards and thenapplying the rules that are required to operate it.

Q375 Sir Peter Soulsby: Can I follow that up? I donot know if you know the answer to this, but is theretrofitting of this sort of equipment very expensivecompared with the costs of operating aircraft?Mr Hall: Yes, that is one of the arguments that hasbeen put forward for many years. Many of theaeroplanes can last and run through various cycles tobe used for diVerent uses in diVerent places, andwhat we have to acknowledge is that when you havegot highly complex airspace and you are going to runat these sorts of levels of utilisation, you may needtighter rules than you require elsewhere. Much of theinfrastructure in Europe is established around acapability that assumes that there will be radar thereand that radar will see the aircraft and deal withthem. In Australia, for example, there aren’t radarsall over Australia, so they require a completelydiVerent set of equipment to be carried on theaircraft to operate eVectively. It does not mean thatwe want the same rules in every bit of airspaceeverywhere, but it does mean that if people are goingto operate through the systems where the eYciencyof the system relies on everyone being able to operatein the same way then it follows that there should berule-making.

Q376 Sir Peter Soulsby: What I was trying to get theflavour of was whether for the airline operators thefitting of the kit, whether it be transponders or themore sophisticated navigation kits, is actually a veryexpensive process when retrofitting to aircraft overtheir, whatever, 30-year, 40-year life?Mr Hall: They certainly tell us that it is, and it is notjust the fitting of the equipment itself, it is theamount of time that the aircraft has to be taken outof service in order to carry out the work, but, ofcourse, the safety standards are so high that fittingequipment in aircraft is much more expensive than itis doing it on the ground.

Q377 Chairman: The CAA question whether therehave been any real capacity benefits as a result of theSingle European Sky. Do you agree with that?

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Mr Hall: I think that progress to date under SingleEuropean Sky has resulted in many of the serviceproviders, such as NATS, getting together to thinkabout, “Right, from today how do we optimise thesystem? How do we align our routes and make itmore eYcient?”, so the process has started. UnderSingle European Sky I am very confident thatgreater eYciency in terms of airspace will evolve but,more importantly, the future eYciency in capitalinvestment will result in lower costs for increasedcapacity across the system.

Q378 Chairman: So you see it as an eVective project?Mr Hall: Yes.

Q379 Chairman: What are your views of theeVectiveness of the UK/Ireland functional airspaceblock?Mr Hall: We were the first, with the Irish, toannounce a FAB in June last year and we have justdelivered the report for 2008 and a plan for 2009.The structure of the work is such that, with theairlines, we have the military and we have the unionsinvolved in identifying short-term, medium-term

and long-term improvements, and the short-termimprovements are already being considered withchanges to airspace arrangements to allow flights tofly straight across Ireland and as far across the UKas possible towards continental Europe in themorning, for example, without having to turn thevarious corners along the way to stay in line with thecurrent airspace arrangements. At the moment thefocus is on operational eYciency. The next thing wewill have to turn to is how we create more eYciencyin the operation of the ATC arrangements in bothcountries.

Q380 Chairman: Are you confident you will be ableto do that?Mr Hall: Yes, we have got some very specific targetswhich we have set and we are committed to. By theend of this year we will have produced a plan to takeus from 2010 to 2013, which is chosen to coincidewith the end of the SESAR period and theimplementation of the benefits of that, so it is alltimed to fit into the progression from FABs intoSingle European Sky implementation.Chairman: Thank you very much indeed foranswering our questions.

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Wednesday 1 April 2009

Members present

Mrs Louse Ellman, in the Chair

Mr David Clelland Sir Peter SoulsbyMr John Leech Graham StringerMr Eric Martlew Mr David WilshireMark Pritchard Sammy WilsonMs Angela C Smith

Witnesses: Mr Tom Needham, Head of Operations Policy, Airport Operators Association, Mr Tim Hardy,Airside Director, BAA Airport Limited, Mr Paul Kehoe, Chief Executive OYcer, Birmingham InternationalAirport Ltd, Mr Richard Gooding, Chief Executive, London City Airport, and Mr Simon Butterworth, Headof Airfield Strategy and Compliance, Manchester Airports Group, gave evidence.

Chairman: Good afternoon, gentlemen, andwelcome to this Select Committee. I know we seema long way away, but we are not really very far. Domembers have any interests to declare?Mr Clelland: I am a member of Unite.Mr Martlew: I am a member of Unite and GMBunions.Graham Stringer: I am a member of Unite and an ex-member of Manchester Airport, former Chair ofManchester Airport.Ms Smith: I am a member of GMB.Chairman: Louise Ellman; I am a member of Unite.Sir Peter Soulsby: I am a member of Unite.Mr Leech: Because we are talking about airports, Ihave to declare a beneficial non-pecuniary interest ina piece of land surrounding Heathrow Airport.

Q381 Chairman: I would like to ask our witnesses,please, to identify themselves for our record.Mr Kehoe: Paul Kehoe, Chief Executive,Birmingham Airport.Mr Hardy: Tim Hardy, Airside Director, BAA.Mr Needham: Tom Needham, Head of OperationsPolicy, AOA.Mr Gooding: Richard Gooding, Chief Executive,London City Airport.Mr Butterworth: Simon Butterworth, Head ofAirfield Strategy and Compliance, ManchesterAirport.

Q382 Chairman: Mr Hardy, what commercialassurances have you had from NATS that the thirdproposed runway at Heathrow is feasible in terms ofairspace issues?Mr Hardy: I should say that we have had nocommercial assurance, because the process ofairspace design for runway three has not yet beencompleted and it is subject to a number of optionsthat at the moment we are considering along withNATS.

Q383 Chairman: What are those proposals?Mr Hardy: Those proposals will be the eventual splitof traYc, for example, on the new runway, thepattern of the traYc, the number of aircraft that arerequired to cross runways to access that new runway.It is a very detailed piece of work.

Q384 Chairman: Does that mean that you will havea key role in making those decisions?Mr Hardy: Yes, I will.

Q385 Chairman: Does that mean that the statementthat NATS has given to us, that it is vital to schedulebelow capacity limits and that the third runwaycould be used to build resilience into the system, issomething that can actually be put into practice?Mr Hardy: Yes, that is exactly right. We will have tolook at the implications of the traYc that uses thenorthern runway and what that means for theresiliency of the airport as a whole. In fact, as a firststep towards that, we are examining the resiliency ofthe existing two runways now since theannouncement in January.

Q386 Chairman: How far has that discussion gone?Mr Hardy: Again, necessarily in these matters this isa complicated area of discussion. We are some fewmonths down the road with our partners inconsidering the resiliency implications of Heathrow.We expect to have some outline proposals in placewithin the next couple of months. We wish to discussthose with the Department for Transport to get aview from their side on the viability of thoseproposals and whether it ensures the resiliency thatwe are looking for.

Q387 Chairman: Have the Department forTransport given you any indications up to now?Mr Hardy: We have had one exploratory meetingwith the department and we have discussed, in verybroad terms, some of the tactical options that wehave to enable further resilience at Heathrow and,therefore, in a three-run way environment we expectto be able to explore and expand those resiliencyoptions going forward.

Q388 Mr Wilshire: On this subject you have said thatBAA would expect to have a big say in the usage ofrunways. I can understand that. At the moment thetwo runways are used in the order of 98% of the time.There are those around the industry who indicatethat 75% is a sensible maximum. What is your viewof a sensible maximum use of a runway?

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Mr Hardy: I guess the best way to answer thatquestion is that when we go into planning the use ofrunways we go into it in collaboration with theairlines, with NATS and with ACL, the slot co-ordinator, so it is a very community-based approachas to how those runways are used. In terms of thepractical limits, 98%, or thereabouts, is where wehave the best balance between capacity and delay,and that balance between capacity and delay hasbeen established for some 10 to 15 years or so.Having said all of that, there are circumstanceswhere the operation of the airfield becomes morecomplicated in the event that there is any disruption,and there are a number of ways in which thatdisruption can be mitigated in future with the newtechnologies around air traYc management.

Q389 Mr Wilshire: But I am right in thinking that,in the event of a third runway, there will be feweraircraft landing and taking oV from the existing tworunways?Mr Hardy: I think it depends on how the capacitydeclaration is handled. We already know that wewould have approval to go as high as 605,000 ATMsfrom the current cap of 480,000. The theoreticalmaximum of those three runways is 702,000 ATMs;so there is already built into the plans a significantdegree of resiliency.

Q390 Mr Wilshire: Is that a, yes, or a, no, therewould be fewer flights on the two runways?Mr Hardy: Overall, on average, there would beslightly less.

Q391 Mr Wilshire: The flight paths that you woulduse for the new runway would not be the same as forthe old runways?Mr Hardy: No, the new standard instrumentdeparture routes and, subsequent to that, the newdesigned departure routes may follow the sametracks but, on the other hand, they may not; it justdepends on how the airspace redesign aroundHeathrow proceeds.

Q392 Mr Wilshire: So it would be reasonable to saythat fewer flights in and out of the two runways atthe moment would mean less noise for those underthe existing flight paths?Mr Hardy: The balance round the six ends ofrunways would be such that the volume per end ofrunway would be reduced.

Q393 Mr Wilshire: Thank you. Could I next bringCity Airport in on this? We were told in a visit toSwannick by NATS that the consequence of aThames Estuary airport would mean that Heathrow,Stansted and City Airport would have to close, andI am quoting what they said rather than inventingwhat they said. When they gave evidence they back-pedalled furiously on that, saying that it means therewould have to be fewer flights out of City, Stanstedand Heathrow. Which of the two comments thatNATS have made to us is true?

Mr Gooding: Leaving to one side whether such aventure is ever fundable at all and deserving of ourattention, the view that we hold is that the siteproposed for the Thames Estuary airport is actuallyfurther in a straight line away from London Citythan Heathrow currently is. We have found a wayover many years, 25 years almost now, to have amodus operandi with Heathrow which has workedperfectly well, and so, with an airport further away,we should be able to work out a suitable system. Ihave to confess, there is no work going on on this atall because of our scepticism about whether thisproject has any real prospect of ever coming tofruition.

Q394 Mr Wilshire: What about the view aboutHeathrow and Stansted being vulnerable?Mr Hardy: I would echo the comments made by MrGooding. There is no work being carried out at themoment on a new Thames Estuary airport,particularly from an airspace perspective. It is notout of the question that it may introduce new areasof population to noise which are unaVected at themoment. The issue of the proposed estuary airport:we have not yet been engaged on it or what theimpacts to businesses would be.

Q395 Mr Wilshire: It seems, Chairman, that we havethree answers: one is that they would have to close,one is that they would have to reduce and now wehave a third one saying it would not matter. Thematter gets more and more confused. Thank you,Chairman.Mr Kehoe: Can I add a fourth?

Q396 Mr Wilshire: There are several of you. Let ushave a fifth as well!Mr Kehoe: I agree with Richard Gooding in terms ofthe fundability, but if it were to be built I think thereare other issues, not only for Heathrow, Stanstedand London City, but Amsterdam and the BelgianFIR (flight information region), because it is so farinto the channel that the descent routes would needto occur over Belgian and Dutch airspace.

Q397 Graham Stringer: Have all of the airports thatyou represent produced master plans for the use ofUK airspace?Mr Kehoe: A master plan for airspace, no. A masterplan for the ground infrastructure, yes.

Q398 Graham Stringer: Anybody else?Mr Gooding: I think all of the largest 29 airports inthe UK have produced a master plan, as we wererequired to do by the 2003 White Paper, but thatdoes not take account of airspace.

Q399 Graham Stringer: Have the CAA carried outtheir commitment to complete the redesign of UKairspace, as was required in the Aviation WhitePaper, to your knowledge?Mr Butterworth: We have seen no evidence of thatso far.

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Mr Needham: There have been no obvious moves byCAA or DAP to engage with the airport communityon airspace strategy in terms of a national plan.

Q400 Graham Stringer: That is quite worrying, is itnot, because if they are not engaged now, then theymight not be ready for the 2011 White Paper? Is thatyour understanding?Mr Needham: Indeed, that is the vulnerability, but asI believe the CAA presented in their evidence, theirrationale for delaying the future airspace strategywas the decision on runway three.

Q401 Graham Stringer: What are the consequencesfor your businesses of not having that redesign?Mr Needham: What we will have is to continue withthe existing arrangements set down in CAP725,which is the current airspace change documentation,but in terms of a national strategy which the 2003White Paper promised, we would strongly supportthat, particularly as we would then have to interfacewith developments on European airspace asundertaken by the Single European Skies andCESAR initiatives.

Q402 Graham Stringer: I understand that those arethe objectives. What I am trying to get at is whetherthere are any good impacts or bad impacts on yourbusiness of the failure of the CAA to redesign theairspace?Mr Butterworth: The straightforward consequencesthat we will see are that we will continue to see theamount of delay that we currently have in thesystem, we will probably see an increase in that delayas traYc growth returns to the industry and we willnot be able to take advantage of the potentialenvironmental benefits that can be gained bypotentially changing airspace.

Q403 Graham Stringer: Is it possible to quantifythose impacts? I appreciate that answer, and it is veryvaluable, but it would be even more valuable if youcould quantify the cost to the environment—the costin time and the cost in delays. Is there any workbeing done on that?Mr Kehoe: Not at this stage, but I think you areabsolutely right to ask that question, because the keyis that with uncertainty comes commercial risk andcommercial risk equals cost. We are without anenvironment or a framework. We have a verysensible White Paper on the ground, we need to beable to launch the aeroplanes that we are planningfor on the ground into the air but there is adisconnect between the two at the moment and withthat there is uncertainty.

Q404 Graham Stringer: That is very helpful. Can Imove on to monetary aspects? In some of thesubmissions there have been complaints that there isinflexibility with the use of military airspace. Canone of the witnesses tell me what the real problem isand what they would like to see in terms of thechange of civilian airspace and military airspace?

Mr Kehoe: I think the airspace breakdown is roughly40% which is used by commercial aviation and 60%which is Class G, or the open FIR, which is also usedby the military. There is a question, I think, that if theRAF has reduced in size over the last 20 years,because of a lack of a cold war, from 90,000 down to30,000, there must be a consequent reduction in thenumber of aeroplanes flying, and many of those thatare flying in the UK, presumably, are in support ofoperations in Iraq and Afghanistan. One has to begthe question, why do they need the large requirementof airspace for purely air defence in the north andtraining in the Midlands and East Anglia? I thinkthere is a question over the allocation of airspace formilitary uses going forward.Mr Butterworth: Can I oVer a specific example ofthat? What we are seeing in Single European Skies IIand the general requirement for more eYcient use ofairspace, and more eYcient public transport by air ismore ability to do point-to-point traYc. That is notpossible with the current design of airspace becauseit forces aircraft to fly down specific corridors,avoiding other areas of protected or restrictedairspace. A specific example may be that to fly fromHumberside to Jersey you currently have to route viaNorth Wales, which is not a direct line of sight.

Q405 Graham Stringer: Clearly not. I know verylittle about this, but my children would say it doesnot seem fair, the allocation of 60:40. When you lookat the actual number of aeroplanes, it must be vastlyweighed down on the side of commercial flights. Doyou know of the justification for that balance andwhat do you think the right balance of the allocationof airspace should be?Mr Butterworth: If you look to the response that theCAA, Department for Transport, the Department ofAirspace Policy gave you, it was that they feel thatthey are acting in Government policy interests interms of how they find a policy in the use of airspace.Our opinion is that there is a wholesale need for areview of that given that things have changed overthe decades, and if we are going to adopt a use ofairspace which is compliant with the future needs ofenvironment and Single European Skies, then itneeds to be under a strategic framework of a masterplan that allows the best benefits for users.

Q406 Graham Stringer: I understand from mybriefing that commercial airliners are allowed to usemilitary airspace at weekends. Is that of any use?Does it make much diVerence? Is it helpful? Couldthat process be followed for the other days of theweek?Mr Gooding: I think it is diYcult to be able to counton it, and that is the trouble. Also, the weekends arethe time of lowest business traveller use of aircraftanyway, but the real thing is the lack of certainty. Ithink the military appear to feel that they are beingsensible and flexible, and from their viewpoint I cansee that, but from our point of view and, moreimportantly, our airline customers, we cannot counton it.

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Q407MarkPritchard:MrGooding,howwouldano-fly zone over Parliament impact on your business?Mr Gooding: At the moment one of our arrivalroutings passes not very far from here; so we wouldhave to move it. That is a rather simple example. Wedo have arrangements, in times of heightenedsecurity, to not fly over this area and, if there was anemergency situation, we would trigger thosearrangements. If this was a long running situation,then we would have to sit with our colleagues inNATS and Department of Airspace Planning tofigure out what we would do.

Q408 Mark Pritchard: Would it impact on yourbusiness?Mr Gooding: In the short-run, clearly it would be anuisance andbe highly likely to impact. In the longer-run, we have for a long time had to fit ourselves into azone thatwas inotherpeople’s zones, so weare ratherused to having to behave flexibly and make changes.We would need to go through the process as outlinedin CAP725 to achieve that.

Q409MarkPritchard:Thankyou.MrHardy,areyoupleased or displeased with the CompetitionCommission’s findings with regard to competition ofBritish airports? Are you content see Gatwick andStansted sold oV?Mr Hardy: I think as far as the CompetitionCommission’s findings are concerned, in generalterms we have been disappointed by the way in whichthe conclusions have been reached. Nevertheless, wetookthedecisionback inSeptember tocommence thesale process for Gatwick, in advance of theCompetitionCommission’sfinalreport, andweareatthe moment considering the options around thereport that has now been presented and will get backto the Competition Commission by the due date withour view of how the rest of the divestment shouldproceed and what our actions would be as a result.

Q410 Mark Pritchard: Of course, you may bedisappointed by the Competition Commission’sfindings. Some of us were disappointed thatHeathrow was not thrown into the mix as well, givenBAA’s (in my personal view) poor customer servicelevels. Maybe there will be an opportunity for that tohappen at another time. Edinburgh or Glasgow:which would be your preferred option?Mr Hardy: I have to say very much the same answer.We are considering ourproposals at the moment as towhich of those two airports would be the one that wewould propose to be divested. That work has not yetbeen completed.

Q411 Mark Pritchard: Mr Needham, clearly I shouldthink your members would want to see, and wouldwelcome, more competition?Mr Needham: I have no evidence to present to youthatwouldsupport thatposition.Weare simplyat thepresent time awaiting developments. You have othermembers sitting inBirminghamandManchesterwhomaywishtoexpressan individualview,but in termsofa collective view outside of BAA, I am not able tocomment on that.

Q412 Mark Pritchard: Can I glean from your answerthat your members, the Airport OperatorsAssociation, are very relaxed about the lack ofcompetition?Mr Needham: I do not believe I said that. I think thatwhat we have within the UK airports community is adynamic and competitive market place. There havebeen questions raised about the position of BAAwhich have been addressed by the CompetitionCommission,but in termsof theoverallmarketplace,I believe that we have a competitive and contestablemarket.

Q413 Mark Pritchard: So you think the CompetitionCommission got it wrong on the monopoly point?Mr Needham: I did not say that.

Q414MarkPritchard:No,butdoyou think theydid?Mr Needham: I would prefer to give that questionsome more consideration before responding, to beperfectly frank with you.

Q415 Mark Pritchard: Would you be prepared towrite to us on that?Mr Needham: I think so.Mark Pritchard: Thank you very much.

Q416 Mr Leech: On the point of competition, ifcompetition is widened in the south-east, will thatpotentiallymake itmorediYcult in termsof theuseofairspace if you have other airport operators vying foradditional business and additional traYc?Mr Needham: I think the key to the future on thatquestion really is thedevelopmentofaviable airspacestrategy for the UK as a whole. I think that the futureairspace strategy which the CAA are speaking aboutwill concentrate very heavily on the congestedairspace in the south-east, and what we are hoping isthat the outcome of that will be a sustainableframework within which all airports can operate.

Q417 Mr Leech: If there are lots of diVerent airportoperators, as opposed to a smaller number, is therethe potential for making it more complicated to dealwith airspace?Mr Needham: There are not going to be any moreadditional airports.

Q418 Mr Leech: No, diVerent airport operators whomight want to compete with each other.Mr Needham: I donot seehow that wouldnecessarilyimpact upon the airspace, but maybe my colleagueshave diVerent views.Mr Hardy: I would say that the three Londonairports, to take those first—Gatwick, Stansted andHeathrow—serve a variety of markets in their ownright anyway. If the competition resulted in themtaking diVerent chunks of their individual marketsand using that as a competitive framework, I do notthink it would necessarily change the way in whichairspace ismanaged, controlledanddelineated, it justdepends on the overall volume of traYc coming intothe south-east of England, which in itself is achallenge now for all of the airports in the south-east;not just because one airport is a competitor to

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another, it is a problem that we all share, and, inresponse to thisparticular inquiry, one thatwebelievestrategically should be held by DAP.

Q419 Mark Pritchard: Two brief final points. MrKehoe, regional airports are more and moreimportant. I justwondered whetheryouwould like tocomment on whether, with the increased traYcforecast for Birmingham and the extended runway,there is likely to be a significant or perhaps a slight(whatever option you wish to choose) use of airspaceand will entry to Birmingham via the County ofShropshire, in particular the Shropshire Hills area, amassive area of outstanding natural beauty, beimpacted or will the heights be maintained at currentlevels?Mr Kehoe: There is an issue with Birmingham lyingbetween two very high-level and dense traYc areas,Manchester to the North and the London TMA tothe south and, therefore, we do tend to get squeezedfrom time to time. The other factor, of course, is thatour runway liesatavaryingdirection thanmostof theother runways in the UK. We are roughly north/south, where most are east/west (and that is a fact ofhistory), and so there are some complex issuessurrounding the Birmingham airspace. I do not thinkin the short-term there is a need or, indeed, a plan thatwe have looked at for our runway extension to starttaking in large amounts of airspace to the west of usoverShropshire.There is suYcient capacity,providedthat there are other things happening in the networkthat will allow that to happen.

Q420 Mark Pritchard: Mr Hardy, this committeesomeweeksagosuggested thatPresidentObamamaywish to use a diVerent airport to come to the countrytominimisedisruption to thegreatBritishpublic, andI am glad that he has taken the advice of thiscommittee and come through Stansted, but werethere any disruptions to the travelling public atStansted as a result of the President’s visit?Mr Hardy: I understand the visit went well yesterday,so there isnoreason to suspect there shouldhavebeenany over disruption or overly-disruptive events as aresult. What I think was important is that the overallvolume of visiting traYc to the UK was spread over anumber ofairports and not just focused, for example,on Heathrow.

Q421 Graham Stringer: I have two follow-upquestions. Mr Kehoe said that Birmingham isdisadvantaged because you are sandwiched betweenManchester and London.Mr Kehoe: We can be, yes.

Q422 Graham Stringer: In Manchester there is recentevidence, they say, that they are disadvantagedbecause priority is given to the south-east system.Could you both expand on that a little bit, becauseyou are both claiming disadvantages and I would beinterested to hear that exposed a little more?Mr Kehoe: I think in the food chain I am at thebottom, Manchester is above me and the TMA atHeathrowiscertainlyabovethem,but thereare issueswithin the system in terms of the problems that are

occurring at Birmingham are as a result of capacityissues at places like Clacton-upon-Sea, so theairspace above Clacton-upon-Sea may have animpact on the arrivals and departures through flowcontrol at Birmingham. Therefore, what we aresaying is that we would like to have equal rights tothat airspace, but I am sure there are equal issues interms of the London TMA and the airports at Lutonand London City versus the other three BAAairports.Clearly,aswegrowuptoour205,000 limitasto air transport movement, we want to be able withsome certainty to have the ability to grow into theairspace, and that is the thing that we are uncertain ofat the moment, because there is no national plan, andwe do need a master plan that follows the AviationWhite Paper.Mr Butterworth: I do not agree. I would not say thereis any particularly hierarchy between Birminghamand Manchester. Perhaps it is a question that NATSmight be able to answer, given they operate the traYcof all those airports and at the high levels across thewhole of the UK. Our concern is that the airspacechange process that we are currently required to gothrough is extremely complex and lengthy and it hassome measures that aren’t necessarily defined wellenough in terms of how you balance them. That isleading to a situation where we have got someairspace change in the south-east that is goingthrough an extremely lengthy debate, and has beenongoing for upwards of seven or eight years now. Theknock-on impact of that is that the airspace changethat follows on from that is expected to be in theManchester terminal area. We were expecting that totake place in the next few years, to take eVect fromabout 2012. Given the delays of the airspace changedown in the south-east, we are expecting that to be tobe delayed by up to two years at the moment already;so our real concern is that, without a nationalstrategic framework to the airspace that is requiredacross the whole of the UK, we do not see an end tothat problem being resolved.

Q423 Graham Stringer: That comes back to thequestions I was asking previously of the CAA notgetting on with the re-designation of their plans.Mr Butterworth: I think all my colleagues wouldshare the same view, that we do not have a nationalairspace strategy that matches that of the WhitePaper on airports.

Q424 Graham Stringer: That is an important point.One final question. What underlies all of this is theestimates in the White Paper that in ground terms, in20 years’ time there will be half a billion passengersusing UK airports. Do you think the figures in the2003WhitePaperare still credibleand, if theyarenot,what figures would you replace them with?Mr Needham: Certainly we believe that those figuresare credible. We believe that they are viable and webelieve that the current economic circumstances maysee growth slow, but all the evidence is that whengrowth is slowed it has recovered and gone to thelevels as forecast. Forecasts clearly can be wrong, but

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we believe that the general approach of the WhitePaper is correct and that the forecasts presented arestill viable.

Q425 Graham Stringer: Is there not evidence fromthe first Gulf War and the SARS epidemic that whathappens as well is the slope of the growth returns;you hit the projected targets later?Mr Needham: Possibly.Mr Gooding: That is true, but we need to bear inmind that the White Paper proposes not providingsuYcient capacity to meet that market demand. Soif the figures do not get to where they might havedone, we will see actual demand coming down nearerto the capacity that is available. At the moment thereare 30 million passengers a year in 2030 who are notaccommodated.

Q426 Sammy Wilson: Following on from that point,if the capacity of the airspace is not going to growand you do not believe it can grow in line with thenumber of people who wish to fly, one suggestionthat has been made—London City have suggestedthis—is that perhaps we need to give some priorityto various types of flights. The suggestion was putforward that perhaps for business passengers, or forflights which are delivering business passengers,some priority should be given there. Can youelaborate on that? First of all, how practical is it toseparate flights in that way and, secondly, how doyou believe that priority would influence the use ofexisting airspace?Mr Gooding: What we were trying to illustrate wasthat there is a current shortage of capacity in themarket place in London and the South East, even inthe current economic circumstances, because we stillsee delays and what is called flow control, which iskeeping the aircraft on the ground at the other endbecause there is not a slot available. That is stillhappening today. That is how the excess of demandis being dealt with now, which is essentially to forma queue. A perfectly legitimate solution to an excessof demand is to form a queue, but we want todemonstrate that there may be other ways ofaddressing the mismatch between demand andsupply. One which we are all bought into is that thereshould be suYcient supply of capacity to actuallymeet the demand, because there are so manydownsides to not meeting that demand. What weillustrated with business travellers was that “a way”,not “the way”, of achieving a balancing up betweensupply and demand is to prioritise certain types oftraYc. It is matter of opinion whether business travelis the right one to choose or not, other people mightchoose diVerent ones, but I was merely trying toillustrate that that is the consequence of not meetingthe demand with airspace capacity; that we have tohave some version of rationing.

Q427 Sammy Wilson: In practical terms, though,can you divide flights in that particular way? Canyou take flights that come into particular airportsand say they are such a homogeneous bunch of

flights that that, therefore, they have less prioritythan others, whether it is business passengers, touristpassengers or whatever?Mr Gooding: Mostly you could look at this on thebasis of whether it is an air transport movement ornot. Is it a movement for hire? That is a fairly easydefinition to strike. I am not pretending that mysuggestion is easy or simple, because it is not, it hascomplex implications and other people have viewsabout it. What I am trying to illustrate is that if wedo not meet the demand, we need some form ofrationing. My suggestion may or may not be theright one and there may be others, but we will needto have one if we want to meet the demand. The viewof my colleagues here, I think, is that the priority forgovernment is to meet the demand.

Q428 Mr Wilshire: Collectively I think yoursubmission, and those of others, have two recurringthemes. One is concern about the strategy for thefuture and the other is about the change processitself. There are three questions that have occurred tome on this. The first is that several of you have saidthat the change issues with airspace represent “ahuge commercial risk”, not having an answer to thechange process at this stage. Could you tell us why itis a huge commercial risk?Mr Kehoe: Because it is aVecting us as we speak. Lastnight Solihull Council gave us permission to extendour runway. That permission has to go toGovernment central oYce for the West Midlands,and we hope that will be a formality. Myunderstanding is that the current CAP725 processthat we will now need to go through to redefine theairspace for that 400-metre extension requires us tobuild the runway and then seek permission for theairspace change. Of course, my board would notsanction the build of that programme without theairspace change being in place, knowing withcertainty they were going to have it. So I think whatwe are looking for from the CAA and DAP isleadership and having a framework whereby wehave already agreed the elements of our master planon the ground and in the air and that the planningpermission that we have now received last nightwould unlock the airspace elements and allow us toproceed with certainty.

Q429 Mr Wilshire: Have others got experience ofthat sort that they can add? No? Another of thecomments being made along these lines is that theuncertainty about both the strategy and the changeleads to delay in taking investment decisions. Do wehave any examples of that that will support theassertion?Mr Gooding: I think, as we go forward, we are moreand more seeing that we cannot build any moreinfrastructure on the ground unless we have gotclarity of view that the airspace will match it, andright now in the little world I occupy we have slightlymore capacity on the ground than the airspace canfeed us. So there is absolutely no argument, howeverkeen one’s shareholders might be, to invest in furtherground infrastructure to meet whatever demand willbe unless I can match it up with the airspace.

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Q430 Mr Wilshire: One of the sorts of points that isgoing to be made in detail is that the costs can behuge in getting to a stage where you can get ananswer. Is anybody able to give some indications ofthe costs that have to be risked in order to get thesethings to a point where air traYc control can bebrought to bear?Mr Gooding: It is multi-millions. We are talking lotsof money. I think it is diYcult to just pluck a numberout of the air, but it is big money. An expansionwhich we recently carried out which required, notDAP approval, but actually SRG approval, we havespent our £30 million building the project and thenSRG, part of CAA, come and approve its use. Thatis a big risk for a relatively small company.

Q431 Mr Wilshire: Does anybody in BAA have anyfeel for a ball park figure of the costs involved ingetting to the stage of a runway at Heathrow beforeNATS would engage with you?Mr Hardy: In our preparatory work for the thirdrunway we have spent, as Mr Gooding says, multi-millions of pounds on the programme to date and,therefore, we are already at risk for those amounts.In reality, as far as our customers are concerned, theairlines, at some stage we will have to draw the lineunder these investments and recover it somehow.There is some degree of doubt about how that wouldwork going forward. The trick, obviously, with thenew runway will be to make sure that we have theprocesses of planning and airspace approval runningin parallel so that we do not extend the risk anyfurther, but it has to be said that, thus far, prior tothe Government’s announcement in January aboutrunway three, we had already spent a number ofmillions of pounds on the preparatory work.

Q432 Mr Wilshire: If I could put to one side for aminute the debate about the desirability or otherwiseof expanding airport facilities and just focus on if weare going to do it: is it reasonable to suggest that theway in which we do airspace work at the momentdelays the actual physical process of delivering whatwe have decided we are going to deliver?Mr Gooding: It certainly can. It has the potential todo that and sometimes, I think, it does.

Q433 Mr Wilshire: Has it done so in the past? Arethere examples?Mr Gooding: I think the past has been very much abook of chapters, where each chapter has been apiecemeal solution to the problem. We are sort ofrunning out of piecemeal solutions, which is whyyou have heard so much from all of us today alreadyabout our keenness to see a national strategy for this:because the previous localised piecemeal solutionsare no longer feasible or as feasible.Mr Hardy: Can I add to that and say that some ofthe impact of these delays is not immediatelyobvious, but actually, in terms of the travellingpublic, delay is clearly the output of anyprocrastination about approval of airspace redesignand, obviously, as far as sector lengths areconcerned, it makes for a very ineYcient air traYcsystem to have airspace that should be redesigned

being held up by a process. That just results, as I saidbefore, in delay. It may not be immediately obvious,but the travelling public are experiencing it rightnow.

Q434 Mr Wilshire: The third of the questions Iwanted to pose to you is about your thoughts onwhat NATS say when one raises this issue with them.The answer that I have heard from NATS when onesays why do not they engage at an earlier stage is thatto do that sort of thing would be hugely costly anduntil they knew what you wanted to do they wouldfeel unwilling to spend money ahead of the decision.This sounds a bit like chicken and egg. Would youcare to comment on NATS’ view of why they do notdo it in a diVerent way?Mr Gooding: I am somewhat surprised to hear that,because the one thing that I have learnt about NATSis that they are really good at sending invoices.

Q435 Mr Wilshire: But that is not the same thing asspending money.Mr Gooding: No, but we have engaged them, in asense, as private consultants in order to advise onexactly these matters. So they are not taking the risk,we are paying them to do that sort of redesign work.Mr Butterworth: One of the things underlying ourconcerns about the development of the futurestrategy for the use of airspace is that it currentlyseems to be devolved to NATS, and whilst they maybe the best body of expertise to deliver that, clearlythey are a commercial organisation and they havegot some concerns about where they are going torecoup the benefits of that. Our view in the utmostsense is that the price really has to be paid bygovernment for putting together that overview ofthe strategy of how airspace is divided up and usedacross the UK.

Q436 Mr Wilshire: You think the taxpayer shouldpay rather than the airlines, the airports and thepassengers?Mr Butterworth: Ultimately everybody will benefit.

Q437 Mr Wilshire: But this should be paid for bytaxpayers, not by the users?Mr Butterworth: The development of theoverarching strategy, we certainly believe, ought tobe funded publicly, centrally, because it is of benefitto the overall airspace of the UK, which is a nationalresource.

Q438 Ms Smith: Going on from that, I hear whatyou say there, but somebody said earlier, I cannotremember who it was frankly, that we need masterplans for both infrastructure on the ground and useof airspace; the two are inseparable in many ways.The new national planning agreements that came inwith the Planning Bill would obviously be a way ofdoing that and would take a lot of pain out of theplanning system in many ways and solve theproblem that was mentioned here. Do you think,though, that under such a system the Civil AviationAuthority should be responsible for developing suchnational planning statements, not agreements, and

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do you think attached to that would be the cost ofdeveloping planning permissions for infrastructureon the ground? Surely it should not be the taxpayerthat should pay for that kind of development interms of planning permissions and all the rest of it?Mr Kehoe: I think there is a view that the developershould pay. I think we are agreed on that. If we aredoing work on the ground that has an impact in theair, I think we have to pick up that bill. I think wherewe are coming from is that there is no nationalframework into which to launch anything, and Ithink the Government has a duty to set theframework, as they have done so well with theAviation White Paper, and we are launching masterplans at our cost into that framework.

Q439 Ms Smith: But the framework itself wouldinclude a degree of work that would traditionally beundertaken by planners, in consultation with peoplesuch as yourselves, and in that sense it is not as clear-cut as you would like it, I believe. Surely it is not asblack and white as you would have us believe interms of cost.Mr Kehoe: There is another issue, in that if I make adecision to do something on the ground here, it maywell impact on my other colleagues. There has to bea sort of super-national organisation that can lookdown and make sure that the plans I am doing do notimpact adversely on Heathrow or Gatwick. So we doneed this overarching organisation.

Q440 Ms Smith: I go back to my point. Theoverarching organisation under the terms of the newPlanning Bill, as I said earlier, would take some ofthe pain out of the current planning system, andsome of the responsibilities currently undertaken atlocal level would go to national level. Surely some ofthe costs attached to the current planning system,which would then go national, ought to be met, asbefore, by developers on the ground?Mr Butterworth: I think there is acceptance at locallevel that the airspace changes required for certaindevelopments at each location should be borne byeach location. The diYculty we have is that with anumber of developments across the UK that areincluded in the Air Transport White Paper, acrossthe whole of the UK, there are so many of them thatit is diYcult to determine who is responsible forwhich piece of capacity growth that is required in themain pieces of airspace. It is those major pieces ofairspace outside the local airport area that we aregoing to be saying there needs to be a centralresponsibility for.

Q441 Ms Smith: But the benefit of centralorganisation of strategy and development of masterplans nationally would be felt by airspace users,passengers, everybody, and airport operators wouldbe one of the major beneficiaries, so surely youshould bear some of the cost of it.Mr Gooding: If the overarching authority you aresuggesting is the Civil Aviation Authority, wealready pay for that anyway. That is not agovernment expense, we pay thumping great licencefees to the CAA to cover these sorts of issues.

Q442 Ms Smith: But you may have to pay moreperhaps.Mr Gooding: If we are getting the benefit, there isalready a mechanism by which that may berecovered. I think that probably more addressesyour question.

Q443 Sammy Wilson: On the whole question ofcapacity, given that you have already described inyour answer, Mr Gooding, that we are probably wellover capacity at present, hence the queuing, etcetera, and that we are intending to double thenumber of people flying in and out of the UnitedKingdom by 2030, are you convinced that byintroducing new technology, creating additionalairspace by squeezing some of the military uses, orwhatever, and re-organising the way in which we useexisting airspace that we can create the capacity forthe additional flights that you are predicting underthe strategy at present, or are we still going to haveto find some way of rationing the airspace in the wayyou suggest or other people have suggested?Mr Gooding: It is a cocktail, is it not? There is thecocktail of a mix between the military and civil, thereis the cocktail ingredient of new technology, as youhave mentioned and there is the cocktail ingredientof rationing. I suspect our cocktail has got to haveelements of all of these in it. It is unlikely to be onebroad brush simplistic solution.

Q444 Sammy Wilson: But we should be capable,through all of those things, of creating the ability todeal with the increase in the passenger flow that weare predicting for the next 20 years.Mr Gooding: We should be and we need to rememberthat the White Paper, of course, was consulted onvery widely, including with NATS and the CAA.Had they had genuine fears that it wasundeliverable, I think we might have heardsomething from them at the time.Mr Butterworth: In addition to that, it might beworth looking at the work that Eurocontrol hascarried out in that respect, because they havecertainly looked holistically at the entire Europeansystem in support of the Single European Skiesprogramme and CESAR in terms of quantifying justhow much capacity can be gained and whatthroughput can be managed through that.

Q445 Chairman: Mr Gooding, you said to us in theevidence you have given us that you think thereshould be more preference given to passengers whoare more economically beneficial. Would you tell usa bit more about what you mean and how thatcould work?Mr Gooding: What I was driving at, as I said inanswer to an earlier question, this was an optionrather than a single strand answer, but in selecting aparticular group, and for my purposes I selectedbusiness travellers, not least because we look afterbusiness travellers so I guess I have to declare aninterest at that point, but business travel plays a vitalrole in the economy of the country. We are an island.If we want to be in the international trading arena,we need to have people flying backwards and

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forwards for business purposes, and, therefore, thereis a way to value the contribution of those folk whichis diVerent, I am not saying better or worse, fromleisure travellers. I was just homing in on the factthat if we do not have either suYcient capacity or anorganised rationing system, we are at risk ofdeterring at least those business travellers who are sovital to the economy of the whole country.

Q446 Chairman: How could this actually operate?Have you given any thought to that? What wouldyou do? Would you categorise the planes, thepassengers in them, or what?Mr Gooding: I think all of those are open toexamination. At the moment it is almost a free-for-all to join the queue, and maybe a queue is not theright answer if we have a shortage of capacity. To goback, I am not really advocating this sort ofdiscrimination at all, because I do not favourdiscrimination on that front, but we have gotdiscrimination by default, we have got long queuesof aeroplanes waiting to come to our airports andland at them. From an environmental viewpoint,from a business viewpoint, that cannot be right. Ifwe are to go forward with a constant forecastundershooting with the supply of capacity, we aregoing to have to have some form of rationing. Eitherwe have rationing as it is practised today, which is tojoin a queue, or we find some way of discriminatingbetween classes of traYc. I am not really advocatingdiscrimination at all, because I think it is utterly thewrong way to go, because it implies constraints inour economy that should not be there.

Q447 Chairman: So it is an aspiration rather than aproposal?Mr Gooding: It is an illustration of what happens ifwe do not get to the point of having some version ofan overarching airspace strategy document that setsthe policy for us all to operate under.

Q448 Graham Stringer: Three questions and then Ihave finished. Mr Butterworth, you said somethingvery interesting in a previous answer. I was opposedto the privatisation of NATS when it happened. Ihave never been able to find any evidence from mypoint of view that it has not provided the service thatone would have expected it to since it was privatised.You said in an answer to a previous question thatbecause it was commercial, it was operatingdiVerently. Do you think you could expand on that?Mr Butterworth: I think it would be hard to say thatit is operating diVerently. What we have got is aconstraint in the process whereby NATS arecurrently the organisation in the UK that takeresponsibility for the design of the airspace changethat supports the growth and capacity for the UK orbit by bit, in a piece meal fashion, the areas of theUK. Because there is only one organisation enabledto do that and they have constraints in their capacityto deliver that process, it means there is a knock-oneVect to everything else that is behind them in thatchain.

Q449 Graham Stringer: I understand that, but Ithink you said that because they were commercialthey were dealing with those issues diVerently thanthey would have done if they were not commercial.Mr Butterworth: I think the aspect of the responsethat you are referring to there was that in acommercial sense they are concerned aboutincurring high costs for developing a strategic planacross the UK in support of perhaps the White Paperwhen there is no mechanism for them to regain thecost of doing that.

Q450 Graham Stringer: That is helpful. Let me startwith Manchester. Does Manchester operateContinues Descent Approach?Mr Butterworth: We do.

Q451 Graham Stringer: How many of the majorairports the UK do?Mr Hardy: The London BAA airports operateCDA.Mr Kehoe: On an ad hoc basis. Not all approachesare CDA.

Q452 Graham Stringer: Does the AOA?Mr Needham: I think the general position is that inthe large airports, BAA, Manchester, CDA is a fairlywell established procedure nowadays. At theremainder of the airports it is on an ad hoc basis.

Q453 Graham Stringer: I asked previously about thebalance between military airspace and commercialairspace. Is the balance between general aviationand commercial aviation the right balance? Some ofthe evidence we have had seems to indicate that toomuch space is given over to general aviation. Theyare our next witnesses, so if you want to saysomething now is the time to say it.Mr Needham: I think the point that we would like tomake on general aviation is that we have workedvery, very hard over the last few years to develop newarrangements for air traYc services outside ofcontrolled airspace, and they have now been inoperation for about two weeks—they actually cameinto eVect, I think, on 12 March—and that is asignificant step from the commercial sector which isfor the benefit of general aviation, largely. So I thinkwe are working with our partners in generalaviation, the businesses in the general aviationcommunity, to provide services.

Q454 Graham Stringer: Anybody else?Mr Butterworth: In the Manchester area we arecurrently completing, or NATS on our behalf arecompleting a process of airspace changeconsultation to actually reduce the area of controlledairspace around the Manchester Airport area,thereby giving back parts of the airspace for generalaviation use and for their benefit and eYciency; so Ithink there is evidence there that we are doing asmuch as we can to aid general aviation. Clearlysomebody somewhere might need to take a view onwhere the conflict arises and who should benefit ifthe conflict should arise.

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Q455 Graham Stringer: This is a technical area. I donot know about other members of the committee,but I find it diYcult. Can you marry it up? You wantmore military airspace on the one hand, but you arehanding over space to general aviation, just onservice, but this appears to be a contradictorypolicy?Mr Butterworth: It might be of value if we could justestablish what is meant by “general aviation”. It isquite a wide-ranging statement. It ranges from, ifyou like, recreational flying right the way through tobusiness aircraft, and so I think it might be valuableto establish which part of general aviation is theconcern, because I think we would feel that we areserving them all. We operate under a public uselicence; we are obliged to be available to allcompanies on an equal basis.

Q456 Graham Stringer: You are not aware of anyparticular problems within the category “generalaviation”?Mr Butterworth: I think it depends which area ofgeneral aviation you might be talking about. Ourview is that they are well represented on the nationalcommittees that look after airspace and air traYcmanagement with the DAP, and if you look at theamount of airspace below, let us say, six or seventhousand feet, where most recreational flying takesplace, there is not a great deal of airspace thatexcludes them at all.

Q457 Sir Peter Soulsby: I would like to go backbriefly to the question that Graham Stringer askedabout continuous descent approach. Do you haveany figures for the proportion of approaches that arenow CDA?Mr Butterworth: Could I qualify my earlierstatement? Whilst we do operate continuous descentapproaches, at the moment it is largely at night, andthat is because we can only operate it whilst the restof the airspace is relatively uncluttered. To gain themost benefit, I think it is probably worth perhapsturning towards the environmental benefits that canbe gained by airspace change, becauseenvironment’s a critical part of sustainable aviationfor the future. We could get more use of continuousdescent approaches and we could getter betterdeparture profiles for aircraft to operate moreeYcient take-oV profiles if the airspace was diVerentto the constraints that they currently reside within.

Q458 Sir Peter Soulsby: Are there actual figures—Ido not know whether they are in your evidence, butI did not notice them anywhere—of the proportionof particular airports and in general, that are able touse CDA and the constraints that have preventedthose proportions being higher?Mr Hardy: First, I can tell you at Gatwick andHeathrow, for example, the number of CDAapproaches at night is in the region of slightly higherthan 90%. During the day, for the reasons that MrButterworth has mentioned, it is slightly lowerbecause the airspace tends to be more congested. I

think it is an important point to talk about howenvironmental impact could be mitigated goingforward and what the beneficial expansion ofcontrolled airspace might be. We want more andmore traYc to undergo continuous descentapproaches, with the drop-oV in fuel burn and thereduced noise. I think this is an important area tofocus on going forward.

Q459 Sir Peter Soulsby: To pursue the point, arethere any figures either in your evidence or that youare able to let us have?Mr Butterworth: I would be happy to provide somefigures for you.Sir Peter Soulsby: I think it might be quite helpful toknow the proportions at each of the major airportsin general.

Q460 Mr Wilshire: One final question from me,Chairman. I hope I know the answer, but I wouldlike to get on the question on the record. Do any ofyou have any concerns at all that the changes nowbeing looked at can compromise safety?Mr Gooding: I would like to turn that round, if I may.I think they enhance safety, not compromise it.

Q461 Chairman: What other views are there onsafety?Mr Kehoe: I think safety is paramount, and we donot compromise on safety.Mr Hardy: I think the other aspect is, obviously,with new technological advances, with SESARgoing forward, safety will be enhanced even further.Mr Butterworth: Safety is designed into the system.The system of procedures that the air traYc serviceoperators operate under provide for that safety.Those margins cannot be eroded. The consequenceof more flights into the system, as Mr Goodingestablished earlier, is that you get more delay and aqueue in the system, whether that is on the ground orpotentially in the air.

Q462 Chairman: What can you tell me aboutcollaborative decision making? How is that going toimprove on what there is now?Mr Hardy: We have collaborative decision makingpartially installed in Heathrow at the moment andwe have a programme to roll out CDM for the restof the airport some time during the summer.Collaborative decision making means that we canreinforce predictability and consistency inoperation, we can take advantage of capacity moreeYciently than we have done before and it gives adegree of resilience to the operation duringdisruptive events like fog, snow, and so on. So weplace a high value on CDM and we are collaboratingwith the airlines and with NATS at Heathrow tomake sure that is a success.

Q463 Chairman: Does anybody else want tocomment on that?Mr Butterworth: We are just embarking onintroducing CDM at Manchester. It is a very useful

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tool for informing all the parties involved in a flight,whether it be on the ground or in the air, as towhether it is actually going to operate at the timethat it is predicted to. Collaborative decision makingcame around from a Eurocontrol initiative whichwas concerned that, once an aircraft landed on theground, they had no predictability about whether itwould be back in the air at the time that the ATM(air traYc management system) expected it to bethere. What CDM does is it allows predictability andallows eYcient use of the slots in the en-routeairspace to be used that are predicted to be there.What it does not do, unfortunately, is allowadditional capacity in the airspace.

Q464 Chairman: Are there any other comments? MrHardy, in BAA’s evidence you say that the DfT andthe CAA have responsibility to “establish the

Witnesses: Mr Paul Draper, Secretary, General Aviation Alliance; Mr Guy Lachlan, Chief Executive, BritishBusiness and General Aviation Association; and Mr John Brady, Vice-Chairman, Light AircraftAssociation, gave evidence.

Q465 Chairman: Good afternoon, gentlemen. Couldyou introduce yourselves for the record, please?Mr Lachlan: Guy Lachlan, Chief Executive of theBritish Business and General Aviation Association.Mr Draper: Paul Draper, Secretary of the GeneralAviation Alliance.Mr Brady: John Brady, Vice-Chairman of the LightAircraft Association.

Q466 Chairman: Thank you very much. How do yousee the future growth of the general aviation andbusiness aviation sectors in the UK? How do you seethe current situation in relation to growth?Mr Lachlan: The current situation is generally bad.If you look at EUROCONTROL’s figures forbusiness aircraft movements, it shows that the UK isthe third most heavily aVected country in the EU interms of reduction of business aviation movements.I think we are down about 27% year-on-year. If youlook at traYc through Luton Airport, for example,which is one of the most important heavy GA/business aviation type airports in the country, that isnumber one on the hit parade throughout Europewith a decrease of something over 30% year-on-yearin terms of movements. In terms of aircraft flyingand new aircraft sales the picture is uniformlyserious. There are areas that as yet have not been soheavily impacted, like flying training which at themoment is holding up reasonably well andmaintenance in some areas is holding up reasonablywell, but the actual flying and selling of new and usedaircraft is in dire straits right now. As to the future,I think it is very diYcult to make predictions. I wouldagree with some of the assertions that were made inthe previous session about getting back on to someform of growth after this downturn, but exactly whatshape that will take is unknown to anybody,particularly when you add in the eVects of theEmissions Trading System and cap and trade which

weighting put to the various interests surfaced by anairspace change”. Could you amplify what youmean?Mr Hardy: By all means. During the course of anairspace change application, the sponsor for routechanges or airspace changes around the airport is theairport operator, generally speaking. The processcan become very iterative, in other words smallerand smaller considerations need to be taken intoconsideration before the airspace change is actuallyapproved, and so we believe that the DfT and theDirectorate of Airspace Policy have a role to play inassisting with the weighting of the variousarguments and counter-arguments as to why aproposal should proceed, or not, as the case may be.I think the important thing is to make the processmore eYcient and quicker in its resolution than itappears to be at the moment.Chairman: Thank you. Thank you very much forcoming and answering our questions.

will impact our sector, which is the heavy non-scheduled airline sector, more quickly than it will theairline sector.Mr Draper: If you look at the smaller aircraft end ofthe market, there is no doubt that sales have suVered,particularly from American manufacturers. There isno English manufacturer left in the marketplace nowreally for smaller aircraft. There has been a shiftaway from those smaller American aircraft typesinto microlights in the UK where there has beensome expansion. This is proven by evidence of pilotlicence issues from the CAA where over the last eightyears issues of licences to private pilots have gonedown by about 30% and have largely been replacedby what is known as the National Private Pilot’sLicence which has a lesser requirement for a licenceand can be used by people with a lower medicalrequirement. There has been expansion of sorts inthat area. There is also evidence that sales in thesecond-hand market, where a lot of tradingnormally takes place, has slowed significantly justlately. When that will come back will depend onwhen the general economy improves.

Q467 Chairman: You are not making anypredictions on that?Mr Draper: No.Mr Brady: In the sport and leisure aviation area it isquite diYcult to track levels of activity because thereis no recording, but airfields report less activity ingeneral so I think we can say the operation of lightaeroplanes has reduced but, of course, there arerather a lot of them. In the UK register there areabout 1,000 airliners but about 26,000 other aircraftin the UK on the register. In the small aircraft sectorwe think there are about 17,000 powered aeroplanesof one sort or another and another 2,500 gliders, sothere are something in the order of 20,000 aircraftabout, plus lots of hang gliders and paragliders,

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which can fly across country these days. I think a lotof people are going to the cheaper end of the marketbecause those sorts of vehicles can be had for athousand pounds or so and people enjoy their airsports in other ways.

Q468 Chairman: What are your major concernsabout access to airspace? Who would like to give mesome information on that?Mr Lachlan: I would echo some of the points thatwere made in the previous session about the lack ofa joined-up complete strategy for how airspace andground infrastructure should be used. We have asituation where as an airport becomes increasinglycongested, contrary to what we have just heard, oncethat airport becomes co-ordinated non-scheduledtraYc is squeezed away from the airport completely.There is no right to appeal, no other process,scheduled traYc has the right to eliminate non-scheduled traYc. That means that the non-scheduled business type GA migrates to otherairfields and those airfields typically have limitationsabout their use either in terms of operating hours,number of movements per year, or both. That doesnot fit necessarily with the airspace capacity, as wassaid earlier, so you have got very anomaloussituations where you have got fantastic, world classfacilities, such as at Farnborough, which as youprobably know is a purpose-built business aviationterminal of the highest standard, operating from anairfield which has very, very low levels of movementspermitted and it is constrained because of that. Onthe other hand, you have got places like Biggin Hill,which is able to operate a long way under theirmovement limit because their movement limit hasbeen set for historical reasons because it used to bea training field. In all cases, the movement caps onairfields are set in isolation from what makes sensefrom the airspace. That is one aspect. The other oneis the promise of greater and greater integration andeYciency in use of airspace generally throughoutEurope. As you have probably discovered, aviationdoes not fit with national boundaries very well, soour interfaces between UK and European airspaceand how the diVerent blocks of airspace worktogether are extremely important to fix so that thecapacity of the system as a whole can be increased.Mr Draper: If you look at smaller aircraft usingsmaller airfields, many of them are located quiteclose to larger regional airports with large areas ofcontrolled airspace which eVectively limits theheights at which aircraft can enter to gain access tothese airfields and, therefore, there are the practicaldiYculties of operating in weather which is not asgood as one might hope and also obtainingagreements to co-operate with the adjoining airfieldsin terms of air traYc movements and the like. Asthose airfields find it more diYcult to operate andattract users, their income drops and, therefore, it isdiYcult for them to keep in operation. In turn, thatremoves essential—in many cases—airfields towhich business people as well as leisure people canfly and makes the whole transport system morediYcult.

Q469 Chairman: Mr Brady, any special points?Mr Brady: We heard in the earlier session about theamount of controlled airspace there is in the UK. Iwould just like to point out that above 25,000 feetthe whole of the UK is controlled airspace, so theairlines have everything above 25,000 feet. Theairspace is then stepped down towards airports incontrolled airspace across the country. Generallyspeaking, the sport and leisure part of generalaviation flies outside controlled airspace butoccasionally crosses it. We do find that controlledairspace has expanded, we are not quite sure by howmuch and the CAA cannot tell us. I heard in aprevious session somebody said about 60% of theUK in the lower levels was controlled airspace, butI have not been able to demonstrate that; I think theCAA is working on it. We do find that controlledairspace sometimes takes up rather more of thecountry than it needs to. For example, Doncasterhas recently established controlled airspace. It isabout the same size as Gatwick but it only has 2% ofthe number of movements that Gatwick has, so ittakes up a big chunk of airspace that was previouslyopen to everybody. It is now only available bypermission using a radio call. The quota ofcontrolled airspace squeezes general aviation and wehave to live in the open airspace that is left.

Q470 Chairman: Do you think there should be limitson the percentage of controlled airspace for eachsector?Mr Brady: We think that the controlled airspaceallocated to commercial operations should beproportionate to the amount of traYc that there is atairports. We know that in some other countries thereare specific points at which controlled airspace ofdiVerent sizes will be allocated to airports, but in theUK we seem to have a standard and, as I say,Doncaster, with very little traYc, has the same lowlevel controlled airspace that Gatwick does, which isperhaps one of the busiest airports in the country.

Q471 Chairman: Would you like to see it controlledby individual airports? That is not feasible, is it?Mr Brady: I do not think we have any problem withthe control of the established controlled airspace atairports because we can always ask air traYc controlfor a crossing clearance if tht is practical. Forexample, the gliding movement may not be able toget a crossing because they cannot maintain heightand are diYcult to integrate with other air traYccontrol. Generally speaking, the general aviationsport and leisure section would like to stay outsidecontrolled airspace where it can share with themilitary but be less trouble to the commercialoperations.

Q472 Mr Leech: Mr Draper, you said that thepressures on airspace had impacted on airfields interms of their ability to make money. Are there anyexamples where airfields have actually closed as aresult of that? Mr Brady mentioned Doncaster andthe restricted airspace around Doncaster. Has thathad any specific impact on particular airfields thatare now struggling as a result?

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Mr Draper: Some of the airfields around Doncasterwere extremely concerned when the proposals werepublished and had very detailed negotiations withDoncaster Airport about their position. In all casesthey managed to reach agreement and the impact onthem is yet to be felt. They had struggles.

Q473 Mr Leech: Are there any other examples?Mr Draper: I cannot give you oV-the-cuV instantexamples.Mr Brady: I can think of a small one. There is aconsultation going on at the moment for GlasgowAirport. Glasgow has three times the controlledairspace of Gatwick and only a third of themovements, but it is currently bidding for a thirdincrease in its controlled airspace which would closethe gap between Glasgow and Edinburgh and wouldisolate the Highlands and north Scotland fromEngland for aircraft that cannot cross airspace,those that do not have a radio, do not have atransponder or in weather conditions they will nothave a corridor to go through. Although they couldgo round the ends, the terrain in a small aeroplane isinhospitable to the west and it is a very long way tothe east. There are also a couple of airfieldsunderneath that controlled airspace which face anuncertain future if the proposal goes ahead. As I say,it is currently under consultation.

Q474 Mr Leech: Manchester has said that perhapsyou are more accommodated than you should beand British Airways have suggested that they areeVectively subsidising general aviation. Two fairlycontrary positions. Who is right?Mr Brady: Can I start with Manchester airspace? Itis not possible to travel through that bit of thenorthwest for a light aircraft except through a lowlevel corridor which is 1,250 feet above mean sealevel, so about 1,000 feet above the ground there is avery narrow corridor between Liverpool andManchester, otherwise you have to go to the otherside of the Pennines and you bump into Doncasterwhich has just been established. NATS very kindlyoVered to give us some airspace and, in fact, theyhave given us 50 feet on the Manchester low levelcorridor.Mr Draper: I have an instrument rating attached tomy licence and to keep that current I need to train atan airfield that has instrument approaches. Basically,we are priced out of the market or not able to gainaccess to airports with those facilities very easilybecause of the presumed amount of usage by them,they just will not let us in. It makes it extremelydiYcult for us to keep current, which we need to doif we are going to fly within the system. There arecertainly diYculties in gaining access to those sortsof airports as far as we are concerned. The otheraspect in terms of the use of the airspace is that wefind in practice it is extremely rare for any airport togive up any controlled airspace, notwithstanding thefact that they now have these continuous descentapproaches, admittedly not 100% as yet, but as theyare coming in there never seems to be any suggestionof them giving up any airspace, and that isregrettable because aircraft performance in

commercial terms has improved considerably overthe years and we believe that it ought to be possiblefor them to give some up, as has technologyimproved to enable them to see what is going on.Mr Lachlan: The point was made in the last sessionabout just how diverse GA is and it is worth keepingthat in mind throughout this discussion because itreally covers everything from powered hang glidersup to Barack Obama’s plane. The heavier end, thebusiness aviation end which flies in and out ofcontrolled airspace all the time, pay the same scale ofcharges as the airlines so there is no cross-subsidisation going on in terms of airspace usage.

Q475 Graham Stringer: Transponders werementioned. Could you tell the Committee what yourattitude is to the CAA’s aspirations to have moreaircraft within the general aviation area fitted withMode S transponders?Mr Brady: I am involved in responding to the CAA’sconsultation on fitting transponders in all aircraft inall airspace in the UK. A transponder responds to aninterrogation from the ground. In general aviationaircraft we have no mechanism for seeing thetransponder returns from another aircraft. Airlinersand business jets and so on actually havesophisticated systems that do that. Our concern inthe open flight information region is that our greaterrisk is close encounters between general aviationaircraft and if they all carry transponders that is notaVected at all because no aircraft with a transpondercan see another aircraft with a transponder unlessthey have the sophisticated equipment which wecannot fit. We thought it was a good thing to havetransponders for carriage in controlled airspace andin other particular circumstances, but to try and fitthis enormous number of aircraft with this veryexpensive piece of equipment for something that isnot completely proven we thought was not aproportionate response. We are still waiting for theCAA to come back and tell us what the outcome ofthat consultation is. We understand they are notgoing to propose any more that all aircraft shouldcarry transponders in all airspace.

Q476 Graham Stringer: You are saying that basicallyyou accept if general aviation goes into controlledairspace a transponder would be a good idea becausethe commercial aircraft would be able to see?Mr Brady: Indeed. A general aviation aircraft goinginto controlled airspace can only do so withclearance from air traYc control, so it has either aradar or a procedural clearance already whichshould keep it clear of other aircraft. The LightAircraft Association took the view that if theweather was instrument flight rules, if it was cloudy,then a transponder would be very important becauseif the procedure broke down then the transpondermight save the day in a collision between twoaircraft. However, if the weather is clear and theaircraft are cleared into controlled airspace undervisual flight rules then we do not believe it isnecessary because we can also use see and be seen asa back-up in the event that the procedural clearancesor radar clearances should fail.

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Q477 Graham Stringer: Is the intrusion of militaryaircraft into uncontrolled airspace a problem?Mr Brady: Most military aircraft do fly inuncontrolled airspace. We share the open FIR withthe military and always have done. Military aircraftsometimes fly in controlled airspace in much thesame way that light aircraft do.

Q478 Graham Stringer: Is flying in uncontrolledairspace a safety problem? Does it cause you anyother kinds of problems?Mr Brady: We do not think so. The Chairman of theUK Airprox Board said that as far as risks withcommercial aircraft there were no risk-bearingencounters since 2006 and for general aviation wenow have the lowest risk for a decade. There hasbeen an awful lot of work going on to educate peopleand improve the radar services that are provided. Itseems to be bearing fruit now because risks andencounters seem to be going down across the board.

Q479 Graham Stringer: I am not clear from thatanswer how much risk there is with military aircraftin uncontrolled airspace.Mr Brady: I do not believe there is any more risk ofclose encounters between military aircraft and lightaircraft than there are between light aircraftthemselves. As was said in the earlier session thereare rather less military aircraft now than there usedto be.Mr Lachlan: In the developments that have justcome into eVect in this country the military havebeen very heavily involved in everything that hasbeen done. I would say that it is a low risk andgetting lower, if anything, because these new servicesare thought out in complete co-ordination withmilitary users of the uncontrolled airspace with aview to making it safer for everybody.

Q480 Graham Stringer: So transponders would notchange the risk of accidents at all? That is the pointI am really driving at.Mr Brady: I think it is fair to say transponderswould, but the improvement in safety across all ofthe FIR would be modest and the costs would beenormous because the cost of a transponder equatesto a fair proportion of the whole value of manyaeroplanes.

Q481 Graham Stringer: You were talking previouslyabout the increase in controlled airspace. Some ofthe evidence we have had, and it might be fromyourselves, is that as the controlled airspaceincreases you are forced to fly lower which has anoise impact on communities. Is that accurate? Isthat true? Can you give us examples?Mr Draper: That would be true in principle.Furthermore, it means that there is more funnellinggenerally, or there can be, of aircraft down a similarroute which poses more noise and also morepotential risk. If you take the example of thecorridor between Luton and Stansted then all traYchas to fly at below 2,500 feet so, therefore, mostaircraft actually fly at 2,400 to make sure they havegot a margin and they follow the same route between

two beacons, generally speaking. The pilots have tobe extremely alert because they cannot always beassured of getting a radar service either fromStansted or Luton because they are busy withcommercial traYc. However, having said that,NATS recently introduced a lower airspace radarservice which might be available to them and whichwe have generally applauded and have been seeking,to my knowledge, for eight years or so, so that is adefinite improvement which helps.

Q482 Graham Stringer: For people under these flightpaths for general aviation, the one you have justdescribed between Luton and Stansted, when thecommercial airspace increases and, therefore,aircraft are pushed lower, is there any form ofconsultation with the people who are aVected by thatnoise or does it just happen?Mr Draper: If there is a request for expansion of thecontrolled airspace then the airspace change processrequires that the proposer, ie the airport, actuallydoes consult with the local authorities.

Q483 Graham Stringer: I understand that and theyare consulting about controlled airspace and theaircraft going through there, but does thatconsultation include the knock-on impacts thatgeneral aviation will have?Mr Brady: I have this to raise with the Civil AviationAuthority tomorrow because within the airspacechange process, which we think is actually quitegood, there is a requirement for the sponsor to lookat the impact on other airspace users andenvironmental issues, but they tend not to do this.There is a consultation going on at the moment tochange the airspace around Stansted which wouldcause more crowding in that gap, but the impact onother airspace users is not actually being considered,so I have to take that to the CAA to draw theirattention to it.

Q484 Graham Stringer: I have been in more debatesthan I would have wished to be about controlledairspace round East Midlands Airport and nobodyhas ever brought up the knock-on impacts of generalaviation, but there is a real issue there, is there?Mr Brady: Yes. If we crowd people together andreduce them in altitude then we increase risk to thatsector and it may be across the piece that is the rightbalance but it does need to be set out and considered.

Q485 Ms Smith: British Business and GeneralAviation Association have suggested that the use ofairspace should be prioritised by the economic valueof the passenger. Could you elaborate on that?Mr Lachlan: It seems to me, as was alluded to in theprevious session, that at some stage we are going tohave the fact that if there are going to be constraintson either capacity or utilisation of natural resourcesat some stage we are going to have to get into somekind of limiting system. Obviously there are severaloptions for how we decide to do that. The easiestwould be just to say that we will make it more andmore expensive and allow those with the deepestpockets to continue flying while those without the

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deep pockets cannot, which does not seem very fair.It seems to me that there ought to be some way ofidentifying the economic value not just of businesstravellers but of all users because, of course, takinga vacation has an economic value, although I do notknow how much that has been studied. Thinkingspecifically about distribution of fossil fuels, we canthen make decisions based not just on who is the lastperson who can aVord it.

Q486 Ms Smith: Within the general aviation sectorthere must be a broad range of the numbers ofbusiness passengers carried, for instance, bybusiness aviation. Can you give me an idea of whatthat range might be?Mr Lachlan: In terms of total numbers?

Q487 Ms Smith: No, in terms of numbers ofpassengers carried per aircraft.Mr Lachlan: It is small. It is something in the orderof three and a half on average. The argument that Iwould put forward is that it is tempting to alwayslook at a full aircraft as being an eYcient aircraft,and of course some entities would encourage thatview, but on some routes it might make sense to justhave smaller aircraft full of people going from A toB. It is a fact of life in the business world you do notalways fly on popular routes. In fact, that is one ofthe rationales of having business aircraft, you areflying to places that are not served by other forms oftravel so, of course, there are not hordes of peoplewanting to go there. That does not mean that thevalue of the flight is low just because there are lesspeople on board, they may be going out to concludebusiness deals that are of very significant economicvalue to the country or to Europe. I wouldencourage a view that moves away from looking ata full aircraft being an eYcient aircraft per se whenI would say if 90% of the people on that full largeaircraft have paid 99p for their seat then I wouldquestion the rationale for burning the fuel.

Q488 Ms Smith: I appreciate that, but surely at theend of the day you would acknowledge that theenvironmental cost of general aviation as comparedto commercial aviation has to be a factor if we wereto get to the point when we had to ration, and I hopewe would not. If we did then the environmental costwould have to be very carefully studied before wemade any kind of commitment to rationing of anykind.Mr Lachlan: Absolutely. All I would say is that costhas to be balanced against economic value ratherthan the number of people on the plane.

Q489 Ms Smith: Are there any studies that you knowof that have taken place to measure this kind ofimpact and then the balance?Mr Lachlan: Yes, at least on the aviation side. A veryauthoritative study has just been concluded byPricewaterhouseCoopers that I think I referred to inmy evidence which is the most recent that I know ofthat has been concluded anywhere in the world. Itwas finished last December. It looks at not just thedirect and indirect value of the flying that is done but

also the induced value of the increased businessactivity and tries to analyse it in a way that is asimpartial as possible. I can certainly provide fullcopies of the report if that helps. I do not know if asimilar report has been done on the airline side. It isnot a straightforward thing to do, of course. The factthat I keep coming back to is if I were to go and buya gallon of fuel and set light to it—not here, butsomewhere—then I am contributing to the GDP ofthe UK because I have bought the fuel, but I havenot put that fuel to any use. I think we need to lookat what use we are getting out of the fuel that weare burning.

Q490 Ms Smith: Is there any evidence to suggest thatthe business aviation sector provides better value formoney in terms of the UK economy than, say, thecommercial sector? Is there any hard evidence toprove that?Mr Lachlan: I would say yes. If you have a look atthis PWc report that I will furnish you with, theinduced value of business aviation to the UKeconomy is roughly equivalent to the total of thedirect and indirect values, so it has a very high ratioof induced value to the value that is generated as adirect and indirect spin-oV from performing theflight.

Q491 Chairman: British Airways have suggestedthat light and recreational aviation is eVectivelybeing subsidised by commercial aviation. Do youagree with that? Mr Brady?Mr Brady: British Airways have proposed this forsome years and, indeed, a few years ago there was amajor study by the Civil Aviation Authority intocross-subsidy within aviation sponsored partly byBritish Airways. The sport and recreational sectorwas excluded from this study which found that wewere subsidising British Airways and the like. Thestructure of CAA costs and charges was changed toput more costs on to general aviation and especiallyon to sport and recreation, and less on to BritishAirways. I believe it is their proper business to goabout trying to reduce their costs and charges inwhatever appropriate way that they can.Mr Draper: We would also say, Chairman, that theyadd costs to general aviation in as much as theyplead for new technology, such as Mode Stransponders and the like, which we require solely toassist commercial air transport. If there were nocommercial air transport we would not need them.Maybe if they want to make more use of thecontrolled airspace and expand it they shouldsubsidise the technology that is required to be putinto our aircraft to allow that to happen.Mr Lachlan: If I can just add that if the non-scheduled carriers had the ability to guarantee theavailability of slots at busy airports which they cancapitalise and use on their balance sheets we wouldvery much appreciate that as well. I sit on the CAAFinance Advisory Committee of the SafetyRegulation Group and can confirm what was saidearlier about the elimination from an airworthinesspoint of view of this so-called cross-subsidy that hasexisted up to now. There is a formula in place that is

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agreed for those airworthiness charges that will seethe elimination of so-called cross-subsidies in thenext two or three years.

Q492 Chairman: What changes would you like to seein the Airspace Change Process?Mr Brady: I believe that the Airspace ChangeProcess is quite good. It was reviewed andcompletely overhauled about three years ago. Weheard earlier that some people would like the processfor Airspace Changes to be set out in advancewithout too much consultation, but we have quite agood and eVective consultation process. The CAAhave stepped back from the airspace design andconsultation area to be the decision-maker and havegiven the responsibility for doing all the work tothose that would have controlled airspace, NATS orthe aerodrome sponsor. We do not have any problemwith that. About the only diYculty we have we havealready mentioned, which is the problem of properlyanalysing the eVect of changes on other airspaceusers, which I hope the CAA will address in thenear future.

Q493 Chairman: Are there any particular concerns?Mr Draper: Yes, Chairman, I think there is anargument which says that the current process putsmore burden on to organisations such as ourselves,which are non-profit making, we are not paid in anyway. We have to keep alert to all these proposals. Wehave to put a lot of time and eVort into dealing withthem. The changes which took place during 2006–07have increased that burden. I think it would be morehelpful if the CAA was more involved in the processfrom the start when the proposer puts forward theirintentions to see that we do not get situations suchas Mr Brady mentioned beforehand, such asGatwick has a very tight controlled airspaceenvironment whereas Glasgow has a very loose oneand wants a much greater area. That somehowseems to be wrong in principle and they should betold that at the outset so that we do not have totell them.

Q494 Chairman: Mr Lachlan, have you anything toadd to that?Mr Lachlan: Again, some kind of frameworkbalance should be incorporated. The process itselfworks very well and the degree of consultation isextremely thorough. I do not know that there is theright balance yet in terms of environmental benefitsbeing reaped by eYcient usage of airspace versus theinterests of people who have justifiable issues aboutnoise or whatever else. I think maybe some morework needs to be done working out some moreclearly stated balance between emissions impact andthe improvements that can be made by sensibleplanning of flight paths.

Q495 Chairman: You also say that there areexcessive volumes of controlled airspace aroundsome airports, such as Glasgow and Doncaster. Whydo you think that has happened? Is NATS using thewrong design principles?

Mr Brady: I can oVer two reasons. Glasgow ishistoric. It has had quite a large airspace. It did havetwo runways and now has one. It has retained all ofthe previous controlled airspace and, in fact, isasking for some more. The Doncaster case is that theCAA applies standard design criteria to controlledairspace which is always 10 miles wide and evenwhen there are very low traYc levels the controlledairspace is still 10 miles wide. In Germany, forexample, smaller airfields get airspace that is only sixmiles wide and it seems to work for them.

Q496 Chairman: You also say that airspace changessometimes force general aviation aircraft closer tothe ground causing environmental damage. Couldyou name any areas where that has happened?Mr Draper: We gave the example earlier, Chairman,of Luton and Stansted. That is a prime example ofwhere we are kept quite low. There are other areaswhere, for example, you are kept to 1,500 feet aboveground, and that is part of what is happening in theother changes proposed at Stansted and alsoairfields around there.

Q497 Chairman: Mr Lachlan, you say in yourevidence that “climate change concerns willincreasingly gain precedence over ‘lifestyle’ views ofconsultees”. What do you mean? What are thelifestyle views?Mr Lachlan: This is not just an aviation related issue;it is the same in many aspects. I appreciate it isdiYcult politically to sell to the electorate.Everybody is in favour of doing the right thing toreduce the level of emission of greenhouse gases butwhen somebody wants to build a wind turbineanywhere near them, they do not like it. When youwant to double-glaze your listed house that you livein you cannot do it because it is a listed house. It justseems that we have not quite got the balance rightgenerally across the piece of saying, “Well, I amsorry, environmental concerns outweigh X, Y andZ”. They might not outweigh everything, but as asociety I think we need to come to grips with the factthat either we are in favour or against doing the rightthing. We cannot be in favour of it if is in someoneelse’s back garden but against it when it is in ourown.

Q498 Chairman: What about flying over nationalparks, say, if it reduced emissions? Would you thinkthat was the right thing to do?Mr Lachlan: I think it should be studied and weshould have clear rules that say if it makes suYcientenvironmental impacts then, yes, it should beallowed.

Q499 Ms Smith: In some cases business travellersusing general aviation could use alternative means toget from A to B, it is not always that there is no otherair or rail means of getting to where they need to be.Surely, therefore, the same principle ought to apply?Mr Lachlan: Yes. I think the air traYc networkshould be looked at in one as a piece of an integratedtransportation network. I absolutely agree with you.

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Q500 Ms Smith: So rationing in the sense that wetalked about earlier would also include a test forbusiness travellers as to whether or not there arealternative means of them getting to where they needto get to?Mr Lachlan: Absolutely. We could all think of areaswhere you clearly would not have President Obamaon a train to go back up to Stansted, so there are linesto be drawn somewhere between me using an aircraftand President Obama, there is a whole range ofpeople in-between and maybe one could draw a line.I think it is an area worthy of study.

Q501 Ms Smith: Is this not an Orwellian approachto running the country?Mr Lachlan: Pass!

Q502 Chairman: Could you give us an example ofwhere an extension of controlled airspace hasrestricted the use of a small airfield?Mr Brady: The current consultation at GlasgowaVects a small airfield which is an up and comingmicrolight centre at Strathaven which is to the southof Glasgow, between Glasgow and Edinburgh, andthe change in airspace proposed will impact on themquite significantly, increase the intrusion of aircraftusing the airfield and make it probably less safebecause generally aircraft will fly much lower thanthey currently do. The airfield owner is currentlydoing battle with National Air TraYc ServicesLimited to try to roll back some of their aspirationsfor increasing their controlled airspace for thatreason.

Q503 Chairman: Mr Draper and Mr Brady, in yourevidence you do not support an Airspace MasterPlan, you think it would “pre-approve” changes.What are the problems that you envisage?Mr Brady: We have talked about the AirspaceChange Process and the consultation process whichinvites views from other airspace users and from theenvironmental aspect. If the changes to airspacewere set out well in advance so that quite long-terminfrastructure plans could be made by airfieldowners and the like then I think that would removethe rather nice democratic process we currently haveof consulting on airspace changes at the time theyare going to be made. The previous group talkedabout the Airspace Change aVecting London North,which is quite important, but that has gone back byseveral months principally because of environmental

concerns and they have gone away to do someredesign to cope with those. Having something thatwas pre-planned and signed oV well in advancewould stop the consultation process.

Q504 Chairman: Mr Draper, have you anything toadd to that?Mr Draper: Only, Chairman, that we are involvedwith NATS in a forum called the GA Forum whichenables us to have discussions with them about theprinciples of what is happening to the airspacestructure and how that would aVect GA. We wouldlike that sort of forum to continue so that we caninput before any Master Plans are actually eVected.In fact, they did talk to us and I was involved in thepreparation of the scoping study, which I believe isstill with Government, to decide on what the futureairspace arrangements for the country ought to be.Once the decision is made on the principles of thatthen we would hope that GA is going to be involvedin taking that a stage further so that the potentialimpact on GA can be considered as part of theoverall plan.

Q505 Chairman: Do any of you have any currentsafety concerns?Mr Lachlan: One example is the carriage of traYccollision avoidance systems—TCAS—in upperairspace is only required on aircraft that weigh morethan 5.7 tonnes which seems to be not perhaps asensible thing to do. Our view as an Association isthat anybody operating a complex jet-poweredaircraft in that airspace, particularly in congestedairspace that we have around here, should becarrying that equipment regardless of the size of theaircraft because a small aircraft can collide with a bigaircraft and they would both come down. That isone.

Q506 Chairman: Any other concerns?Mr Brady: There are quite a number of activitiesgoing on at the moment, one of them sponsored bythe CAA, that seek to improve safety outsidecontrolled airspace. We have seen various reportsfrom the Airprox Board and from others that saysafety is improving steadily year-on-year outsidecontrolled airspace. I am really quite pleased that isthe case.Mr Lachlan: We would agree with that.Chairman: Thank you very much for coming andanswering our questions. Thank you.

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Wednesday 22 April 2009

Members present

Mrs Louise Ellman, in the Chair

Mr David Clelland Ms Angela C SmithMr Philip Hollobone Sir Peter SoulsbyMr John Leech Sammy WilsonMr Eric Martlew

Witnesses: Jim Fitzpatrick MP, Parliamentary Under Secretary of State, Mr Jonathan Moor, DirectorGeneral of Civil Aviation, and Mr John Parkinson, Head of Airports Policy Division, Department forTransport; Sir Roy McNulty, Chairman, and Mr Mark Swan, Director Airspace Policy, Civil AviationAuthority, gave evidence.

Chairman: Good afternoon and welcome to theCommittee today. Do Members have any intereststo declare?Sir Peter Soulsby: Yes. I am a member of Unite.Mr Martlew: I am a member of Unite and GMTUnion.Mr Clelland: I am a member of Unite.Chairman: I am a member of Unite.Mr Leech: Chairman, given that we are talkingabout airspace, I have acquired a non-pecuniarybeneficial interest in a piece of land surroundingHeathrow Airport.

Q507 Chairman: Thank you, Mr Leech. Could I askour witnesses to identify themselves, please, for ourrecords?Jim Fitzpatrick: Chairman, if I could introduce mytwo colleagues from the Department for Transport,Jonathan Moor on my direct left, who is DirectorGeneral of Civil Aviation, and John Parkinson, whois Head of Airports Policy Division.Sir Roy McNulty: I am Roy McNulty, Chairman ofthe Civil Aviation Authority, and with me is MarkSwan, who has recently become the Director ofAirspace Policy, replacing John Ascott, whoattended with me at the previous hearing.

Q508 Chairman: Thank you very much. Minister, weare at the moment in a global recession and air traYchas reduced severely. Why are you so confident thatthe demand for air travel will continue to grow at thelevels you have been predicting?Jim Fitzpatrick: Chairman, I was wonderingwhether it would be helpful to the Committee if I setout briefly the role of Government and the other keyplayers in managing airspace, but if you are happythat you have covered that then obviously I wouldnot want to detain the Committee, but I have got abrief statement of about two minutes. The respectiveroles of the various players have developed overmany years to be complementary and mutuallysupportive. ICAO’s Chicago Convention recogniseseach state’s sovereignty over its airspace andrequires it to arrange the provision of air navigationservices. UK airspace is organised into two flightinformation regions, the London and Scottish FIRs,which extend towards Iceland and Norway to thenorth and to the Channel Islands in the south. TheDepartment for Transport specifies the policy

framework for the use of that airspace, but it is theCivil Aviation Authority, the independent regulator,which designs and implements detailed measures toensure all users are granted fair and equitable accessto it. The CAA is seen as one of the leaders in its field.NATS and to a certain extend the MOD areresponsible for the day to day safety operationwithin the two FIRs. Although each Member Stateremains sovereign over its allocated airspace, it issensible to utilise this finite resource as eYciently aspossible. That is why the UK has strongly supportedthe European Commission’s initiative through theSingle European Sky in encouraging airspace to beconsidered in a wider sense beyond the confines ofnational borders, to improve traYc flows and reducethe negative impact of aviation on the environment.To that end, the UK has been the first to establish afunctional airspace block with a neighbouring state,in this case Ireland, which will deliver gains incapacity, safety, environment and cost eYciency.Eurocontrol, the intergovernmental organisationcomprising 38 states, has enormous airspace and airtraYc management expertise and is ideally suited torealise the initiatives of the Commission. The UK,being a member of both Eurocontrol and the EU, isinstrumental in influencing Eurocontrol’s delivery ofeVective air traYc management measures.Furthermore, the European Aviation Safety Agency(EASA), is establishing common rules for air traYcmanagement and air navigation service safety toensure a high uniform standard of ATMs rightacross the EU. Member States and key industrypartners such as NATS are fully involved and theUK will work hard to ensure that these standards areworld-leading. Thank you very much, Chairman.

Q509 Chairman: Thank you. Could you tell us whyyou remain confident that air traYc will continue togrow as you have been predicting, given that we arenow in the depths of a global recession and air traYcclearly is being severely aVected by that?Jim Fitzpatrick: I think it is self-evident on the basisof the experience of recent decades that air traYc hasbeen growing. There have been some reductions on atemporary basis as a result of circumstances outsideaviation’s control, but generally speaking we areconfident that the range of figures we outlined in the2003 White Paper in respect of the numbers ofpeople who have been using and will continue to use

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aviation will continue to grow. The assessments wehave made within the Department and the evidenceof aviation around the world do give us confidencethat the figures are robust enough to be able to berelied upon.

Q510 Chairman: How often do you go back to thosefigures and look at new predictions?Jim Fitzpatrick: As you know, in the 2003 WhitePaper we said we would produce progress reportsbetween three and five years, so we have publishedthe progress between three and five years. PerhapsJonathan could say how closely we monitor them inbetween the publication of the reports.

Q511 Chairman: When you are answering that,could you indicate how that monitoring is beingaVected or changed by the recession?Mr Moor: Certainly. Since the Air Transport WhitePaper was published in 2003 we have updated ourtraYc forecast three times: in December 2006 at thetime of the progress report in November 2007 and inJanuary 2009 at the time when we published theHeathrow decision. The forecasts are still in line withthe overall range set out in the Air Transport WhitePaper and in January 2009 the central forecastshowed an increase of passenger numbers from 235million passengers in 2008 up to 465 millionpassengers in 2030. That is lower than the range atthe time of the Air Transport White Paper but it isstill within the range of the high and low forecasts. Itis still a very significant increase compared with atthe moment. In the first three months of this yearpassenger numbers are tracking at around the 2006level, so they are less than they were in 2007 and 2008but they are tracking about the same as 2006.

Q512 Chairman: Do you believe that thedevelopments set down in the 2003 White Paper areall still as necessary now as they were then?Jim Fitzpatrick: I certainly do, Chairman, andhaving gone through the Heathrow exercise sointensely over recent years and the figures thatHeathrow are dealing with in terms of capacity, thatclearly indicates to us that we do have a capacityproblem there. Therefore, we do stand by thepredictions and the requirements that aviation willhave to meet as assessed then, as Jonathan has justoutlined.

Q513 Chairman: When you took your decision onHeathrow, did you look at airspace issues?Jim Fitzpatrick: We did. There was some preliminaryairspace assessment undertaken as part of the wholeconsideration of Heathrow to determine whether ornot, where we were required, in our belief, to supportthe additional runway capacity, it could beintroduced safely within the airspace confines whichwere available to us and those assessments werepositive.

Q514 Chairman: Is airspace something which isconsidered after the decision on expansion, or is itpart of the decision itself?

Jim Fitzpatrick: I think it goes both ways,Chairman. The assessment of aviation capacity andcertainly in the national perspective when we aretalking about the assessments we have discussed inthe Planning Bill, the Planning Act last year,national infrastructure projects, when somethinglike Heathrow comes along clearly that takes someconsiderable time. The Heathrow assessment is avery good example of that, how long it took us fromestablishing the consideration, going for theconsultation, assessing the submissions. Airspacechange can be assessed in a much shorter period, sothere was an assessment carried out beforehand tosee if it was compatible, if it could be done safely, andthen in the course of all the planning applicationsand submissions which would have to be gonethrough once the decision in principle has beentaken—which we have—clearly the definedconclusions and adjustments which would have tobe made would have to be undertaken, but they canbe done in a much shorter timeframe.

Q515 Chairman: Sir Roy, are you satisfied with thisprocedure?Sir Roy McNulty: Absolutely. I think it has stood thetest of time. We have had major developments likethe second runway at Manchester. Generallyspeaking, airspace change can be done well withinthe timescale needed to get planning approval and todo the construction.

Q516 Mr Leech: Were any concerns raised at allabout whether or not a third runway would have anynegative impact on the use of airspace or any issuessurrounding safety, or was it a case of, “Well, yes, athird runway can easily be accommodated”?Jim Fitzpatrick: It was an assessment that was madeand the conclusion was positive in that it could beaccommodated. I would not want to suggest in anyway, shape or form, Mr Leech, that there was anysimplicity involved in this. I know you were notsuggesting that. It was a very sophisticated processwhich had to be gone through and airspace changewas one of the elements we had to be confident ofmeeting, so it was undertaken, it was evaluated andwe were confident that it could be done veryeVectively and safely.

Q517 Mr Leech: Have any concerns ever been raisedwhen we are talking about airport expansion, notnecessarily at Heathrow, any other airport? Haveany concerns ever been raised about safety andsecurity of airspace with the planned expansion of aparticular airport?Jim Fitzpatrick: Forgive me, my colleagues will havemore experience in terms of the industry of aviationas I have been there for less than three years.However, there are always concerns raised, in myunderstanding. Whenever there is an expansion thefirst thing people will say is, “Can it be done?” Wewere saying that Heathrow is running at 99%capacity, and I am sure that some people would drawthe conclusion that if you are running at 99%aircraft, how are you going to squeeze in moreaircraft, and maybe make that assessment as being in

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the air, whereas we are talking about on the groundand the ability to land and take oV. Concerns, in myexperience, will be one of the first things that peoplewho are interested will want to ask about and thoseopponents of aviation, I would imagine, wouldalways use airspace as a possible area where theremight be diYculties, but I am not sure what theexperience was elsewhere.Mr Moor: If I could just explain the process atHeathrow. NATS did an independent study basedon the proposals from the airport operator, how theywould operate the airport. That study was publishedat the time of the adding capacity at Heathrowconsultation, so it was freely available during theconsultation process. The CAA were also involvedin the project, the sustainable development ofHeathrow, and therefore took a preliminaryassessment of that study, but this is all subject tomuch more detailed work done at the time of theplanning application because you cannot design adetailed airspace change until the planningapplication is agreed, because that is exactly how theairport will operate. I think in terms of anotherairport, for example a recent application onCoventry airport did have some airspace issues andI think Sir Roy might be able to explain to youexactly the CAA’s role in that application.Sir Roy McNulty: If I might add briefly, youmentioned concerns and I think we see them more asissues to be solved. In the Coventry/Birminghamcase, because of the location of the two runwaysthere was a potential for conflict between them, thattraYc would interfere, coming from one to the other,and in looking at the planning application weadvised that there would need to be constraints onthe way in which the expansion at Coventry could behandled because our first priority is always to ensurethat there is safety. So, where there are issues like thiswe would put in place suYcient constraints to be surethat the system operates in a safe way.

Q518 Mr Leech: Would you ever say, “If you aregoing to build a third runway at Heathrow, that isgoing to seriously have an impact on the potentialfor having a second runway at another particularairport,” because I know there were certainly somecomments made about the feasibility of a newairport in the Thames Estuary and the impact thatwould potentially have on airspace around theSouth East?Sir Roy McNulty: I think that is a correct statement.If a major new airport was developed in the ThamesEstuary it would have implications for London City,for Stansted and for Heathrow, and potentially forGatwick, so there would need to be some adjustmentof the traYc flows but we would always ensure thatwhatever adjustments were necessary and agreedwere made because we would always ensure thatthere is a safe system.

Q519 Ms Smith: DFT evidence acknowledges thatthe third runway at Heathrow could possibly reducestacking, routine stacking, or even eliminate it. Whatdiscussions has the Department had with NATS onthis point?

Mr Moor: Essentially a third runway will give yousignificant more capacity throughout the day. Thereason for stacking is twofold. One is just simply thevolume of the aircraft arriving at particular times ofthe day. There is another reason for stacking, whichis a good operational reason. When the airport isoperating at 99% capacity you need some stacks inthere so that the air traYc controllers can bring theright mix of aircraft into the airport. So stacking isnot necessarily completely negative when you aredealing with a very congested airport like Heathrow.With a third runway you are bringing additionalcapacity and because, on behalf of the Government,the Secretary of State has decided not to release allthe capacity immediately that will give anopportunity for the airport to be run more eVectivelyand therefore to reduce unnecessary stackingbecause there will be a third runway available therefor landing and take-oV.

Q520 Ms Smith: You talk about “unnecessarystacking”. Will you insist on targets to reducestacking?Mr Moor: I certainly think there is an opportunity tolook at setting targets. The CAA has recently done astudy for us on resilience, which will be published, Ithink, fairly shortly. That will look at the economicbenefits of reducing time delays, and obviouslystacking adds to time delays.

Q521 Ms Smith: If they were to be introduced, whichbody do you think should be responsible for settingand monitoring these targets?Mr Moor: I think it is important to look and seeexactly what you are trying to achieve with thetargets and then assessing which body is the mostappropriate body to actually regulate those targets.A lot of performance measures already exist, whichthe airports publish. Eurocontrol publish measuresand they publish targets around time delays. I thinkin terms of any regulation of targets in the future Iwould probably look to our regulator, the CAA, todo that.

Q522 Ms Smith: Any comments from the CAA onthat?Sir Roy McNulty: It is not part of our remit at themoment, but if we were given the remit it is the typeof thing we could readily do.

Q523 Sammy Wilson: Some people say there is muchtoo cosy a relationship between the CAA, theDepartment and NATS and therefore if there is to beregulation it should really be done by some moreindependent body such as the Environment Agency.Have you any comment on whether or not givingover the monitoring of the situation to anindependent agency such as the EnvironmentAgency may well engender some more confidence inthe work that is being done?Jim Fitzpatrick: I would not agree with that, MrWilson. I think the CAA fiercely defends its integrityand certainly its role as regulator is quite wellrecorded. I do not see that there is conflict betweenthe two bodies. I think there is a very solid working

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relationship and I think we are very happy for thatto be examined and scrutinised by anyone. There willalways be some sceptics or cynics who will argue thatorganisations are in too close a relationship, but Ithink the public scrutiny by yourselves and byothers, by the reports published to Parliament, givesthe opportunity for reassurance that there is no waythe arrangement is failing the public, either in termsof professionalism or integrity.Sir Roy McNulty: I would like to endorse thatcompletely and I have had the experience of being inNATS. I was the Chairman of NATS and we havebeen regulated by the CAA. The CAA did us noparticular favours. They are regarded, I think,worldwide as one of the most rigorous regulatorsboth in safety and in other aspects. We have acivilised professional relationship, that is for sure, weare not fighting all the time, but I do not believe thathaving a civilised professional relationship is anysort of crime.

Q524 Sammy Wilson: Leaving that aside and justlooking at the argument in terms of independence, if,for example, it were to go to, or even considerationgiven to the Environment Agency taking on the role,do you believe you would have the expertise?Sir Roy McNulty: The CAA certainly has theexpertise in relation to noise. I think we are amongthe leading experts in the country as far as noise isconcerned, which is one important part of theequation. Given the remit which we are expecting toget in relation to Heathrow and air quality, I have nodoubt we will acquire the expertise. I think our trackrecord as regulator shows that we are independent,we operate in a very rigorous way, we acquire theexpertise we need to do the job and we do it properly.

Q525 Mr Martlew: Can I come to the aspect of thedivision between military and civil aviation? Is thesplit right? My understanding is the use by militaryaircraft of airspace has reduced considerably overthe last decade. Is that correct?Sir Roy McNulty: I will invite Mark Swan in amoment to comment on it, but I assume you aretalking about the division between controlled anduncontrolled airspace. There have been lots offigures bandied about, both in front of thisCommittee more recently and elsewhere. It is quiteconfusing because it depends on what you aretalking about.

Q526 Mr Martlew: Tell us what we should betalking about.Sir Roy McNulty: I can come up with severaloptions. One of the problems when you talk aboutairspace is how far up are you going? As some peopleput it, do you go all the way up to God or are youquantifying something a little bit shorter than that?We have to bear in mind that above 19,500 ft all ofthe airspace is controlled, because that is where allthe international flying takes place, and so on. If youcome down below 19,500 ft, 40% of that is controlledairspace. If you add a lump of the airspace above19,500 ft you can get to 60% controlled but, as I say,it depends on what you mean. Having said that, it is

true that there is less military flying than there was,but I think a very important fact we have toremember is that the type of flying the military aredoing is diVerent. Once they brought in theEurofighter, which has a completely diVerent flightprofile from anything we have ever seen before toexercise that type of aircraft requires a lot moreairspace than the previous less advanced aircraft did,so there has not been a pro rata reduction in theamount of airspace the military use just because theyhave fewer aircraft, but Mark knows a lot moreabout it than I do.

Q527 Chairman: One of the points which have beensuggested to us is that because of your militarybackground perhaps that is indicative of too muchemphasis on the military than civilian aspects.Would you comment on that.Mr Swan: I think I will have to leave others to judgeon my performance over the next couple of years,Chairman, if I may suggest. Yes, I am an ex-Typhoon pilot, so I do have some experience in usingthe airspace. One of the points I would make is thatthe airspace is not denied. None of the airspace isdenied to any user. Particularly the military canregularly fly in controlled airspace. However, theirtraining requirements, their high energy movementsin large formations of aircraft tend to mean that theairspace they utilise, predominantly over the sea andsome of the lesser populated areas of northernScotland for specific low flying training, does notmean to say they cannot have access to other partsof the sky when they need it. In terms of carving upthe airspace, of course most of the military training,apart from designated danger areas, is free airspaceto GA, to gliders, and it is shared. It is uncontrolledairspace, much of it flown in the principle of “see andavoid”, so this idea of percentages implying that acertain amount of airspace, as Sir Roy has outlined,is completely closed to the military and that themilitary can only use another part of the world iscomparing apples with pears to a degree and I thinkcan confuse the debate on who gets to own what andwho uses particular portions.

Q528 Mr Martlew: So can I take it there is noparticular problem?Sir Roy McNulty: We do not believe there is an issue,which is not to say that some users do notperpetually complain about the subject and theylove a debate about whether it should be 40, 60, 55,45 or something, but the CAA has never startedfrom the point of view of, “Let’s decide we will give60 to one and 40 to the other.” The 60/40 is an endresult of a case by case allocation of airspace forparticular needs and making sure that the system iskept safe.

Q529 Mr Martlew: If I can just go on from thatslightly, my experience of military aircraft is inCumbria and it is low flying. We do not see much ofit now, but it is a tranquil area and I think there arecomments here from some of the county councils. I

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am not just talking about military aircraft, I amtalking about overall. What do you do to preservethe tranquillity of various parts of the countryside?Sir Roy McNulty: The main thing the CAA does inrelation to this is handling airspace changes whenthese are proposed. We handle airspace changes inaccordance with a quite detailed set of guidancewhich we get from the Secretary of State, 20 pagesworth, which covers all the diVerent factors we needto take into account. One of those factors istranquillity, but also another factor is limiting thenoise nuisance to large volumes of population, butyou cannot allow one of those factors to driveeverything. We try to arrive at a balanced judgmenttaking those factors into account, together with theneed to move traYc eYciently and the need topreserve safety above all else.

Q530 Mr Martlew: So you do not have anydesignated areas where you say we should not flythere?Sir Roy McNulty: No, we endeavour, in line with theguidance we have, to avoid Areas of OutstandingNatural Beauty and we recognise the desirability ofkeeping tranquil areas tranquil where possible.

Q531 Mr Martlew: The other option is that you giveeverybody a bit of the noise and spread it out?Sir Roy McNulty: Absolutely, and thus annoyeverybody! We do try to avoid that.

Q532 Chairman: Minister, are you satisfied withprogress on developing the Future AirspaceStrategy? There does not seem to be much progressin developing that. Are you satisfied with the workthat is being done?Jim Fitzpatrick: We certainly think that the processworks properly. As Sir Roy has just indicated, theguidance which is issued through the regulator fromthe Department is quite voluminous. The potentialconflict between Areas of Outstanding NaturalBeauty, population centres, et cetera, has to beworked out and we are going to be consulting laterthis year on the guidance in line with therecommendations from the Pilling reports in respectof environmental issues. We are satisfied that theway it has been operated up until this point has beensatisfactory, but by virtue of the fact that aviation, aswe described earlier on, is expanding, the demandsat Heathrow and elsewhere, airspace changeprocesses require scrutiny and consultativearrangements and we have been going through thosein several areas, as you know. There have been lotsof interest groups which have been lobbying stronglythat we should go one way rather than the other andclearly that process seems to have been workingbecause people had the opportunity to express theirviews as to where the change should be and where itshould not be.

Q533 Sir Peter Soulsby: On that, could I just put toyou what the Airport Operators Association said tous? They said they had not been invited to field anyexperts to contribute to this much needed work.They were talking there about the future airspace

strategy. Virgin Atlantic and BA have told us theyhave not yet been contacted about the FAS work.How do you respond to that criticism? Surely theseare major stakeholders?Sir Roy McNulty: I do not think it is entirely fair tosay that nothing much has been done on this front.For the last three or four years, I think, since wekicked oV this exercise, we, together with NATS andthe MoD, have done a number of studies, the majorone of which was done by NATS, what we called a“scoping study. What it showed was that in lookingat this very major exercise, which is looking atairspace needs and policies out to 2030 so it islooking 20 years ahead, the conclusion a year or soago was that there were still too many majorunknowns to carry this work forward meaningfully.For one thing, it was uncertain what would be theoutcome of all of this Single Sky II and SESARexercise in Europe, which will have a major bearingon the way in which we manage our airspace in thiscountry. There has been a debate going on about athird runway at Heathrow, which is a major factor asregards airspace in the South East. There have beendiscussions about environmental climate change andhow that relates to aviation, and that debate is notyet finished. The conclusion between ourselves fromthe initial studies was that it was too early to pushthis forward because there were too many openquestions. We have now concluded that with thedecision on Heathrow and with the conclusions wecan now see on Single European Sky II and SESARwe can see the way forward a bit more clearly, andone of Mark’s initiatives has been to launch now forreal a project definition study on this FutureAirspace Strategy. I think I said at the previoushearing I attended that this is not a short exercise,this will take us two or three years, but consultationwith all of the major stakeholders for sure willhappen, probably an initial round sometime thisyear, and we will take this forward, but it is a non-trivial exercise. This is a very complicated exerciseand it will fully take, I think, the two or three yearsI indicated.Mr Moor: I would just add that we have establisheda joint project board, which is jointly chaired bymyself and Mark Swan and involves NATS as well,to start taking this work forward and developing it.As Sir Roy said, we intend consulting on it at anappropriate time, once we have actually got thework underway and we have something to consulton.Mr Swan: I would just add, Chairman, to echo SirRoy’s comments about the certainty, we are now onan established programme footing with this work, soif I may just answer the criticism, the time simply wasnot right to engage the external stakeholders, whoare very keen to see this work, simply because thereis no point at this particular stage in going to themwith a series of products which, frankly, we could nothave a useful debate over. But we are very keen to gettheir input at the right time and, as Sir Roy has said,that will be sometime soon.

Q534 Chairman: So it has been a matter of timing?It is not neglect, it is just timing?

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Mr Swan: It is timing, Chairman, yes.

Q535 Chairman: We have been told that your 2002environmental guidance lacks clarity, particularly interms of priority attached to environmental impactssuch as noise and emissions. Do you agree with thatcriticism?Mr Moor: We are working on this at the moment aspart of responding to Sir Joseph Pilling’srecommendation on setting the environmental dutyfor the CAA. Project work is being undertaken nowand we are proposing to consult later this year on adraft environmental duty for the CAA which wouldalso include looking at the guidance and how theguidance should be updated in line with that.

Q536 Chairman: When exactly will the Departmentprovide the CAA with an environmental policyframework?Mr Moor: The environmental duty would be part ofan aviation regulation bill and that would depend onwhen parliamentary time is available. The questionis, would the guidance be updated in advance of thatbill or as part of that bill, and I think that issomething we still need to work through with theCAA.

Q537 Chairman: So you do not feel any concernabout the time lapse?Mr Moor: We feel that the guidance at the momentis fit for purpose, and maybe Sir Roy might want toadd more to that.Sir Roy McNulty: I know the sort of statementwhich was made to you and has been made to me,that the guidance is not a formula that you can applyto each and every situation, and I think that is as itshould be. There is a degree of judgment involved inthese things and the environmental considerationswhich would apply to airspace changes, let us sayaround London, are completely diVerent from theconsiderations which might apply, say, in Cumbriaor Scotland. To that extent the guidance is generalguidance, it is not a recipe that solves each and everyquestion, and I think that is the way it will probablyremain because there is no such thing as a perfectformula that solves all the questions we getpresented with.

Q538 Chairman: Should reductions in CO2emissionsfeature much more largely in that?Sir Roy McNulty: Again, that is a question for theGovernment ultimately, but I would imagine, giventhe prominence and importance of CO2 emissionsand given the targets which have now been nailed inplace, I would expect that the new version of this willcertainly give attention to CO2 emissions.

Q539 Chairman: Could I direct that question to theMinister and in answering it, Minister, could you tellus why the 2007 issue of CAP 725 does not mentionthe Stern or the Eddington Reports?Jim Fitzpatrick: I am sorry, I cannot explain why itdoes not mention it, given that it was just as I wasarriving at the Department. My colleagues might beable to answer. Certainly the question of CO2

emissions is certainly much more prominent nowthan even in 2007. The Secretary of State’s statementin respect of Heathrow quite clearly indicates that.The Department’s policy on CO2 emissions asregards aviation where we have been successful inleading the argument for aviation to be included inthe Emissions Trading Scheme within Europe,although we lost the argument internationally atICAO, and the benchmarking of CO2 emissions atthe 2005 average in the future all indicate that CO2

emissions is a very important aspect of aviationpolicy for the Government. I am sorry, Chairman, Iam not privy to why it was not mentioned in CAP725.

Q540 Chairman: Can any of your colleagues give ussome information?Sir Roy McNulty: If my answer is not complete I willsend you a supplementary note, but CAP 725 was re-issued because we had done a review of the AirspaceChange Process. We had, I think, streamlined it in anumber of respects and that was why it was re-issuedin 2007. That is just talking about the process we usefor assessing airspace changes, but the AirspaceChange Process was still being operated under thesame environmental guidance which had been givento us in 2002 and I think anything that needed to bepicked up from Stern or from Eddington I wouldexpect to surface in the new edition of theenvironmental guidance. I do not think there wasanything in either of those reports that changed theprocess we followed.

Q541 Chairman: So are you satisfied then that theCAA’s airspace policy documents do actually reflectup to date Government policy?Sir Roy McNulty: They reflect Government policyas given to us through the environmental guidance.

Q542 Mr Hollobone: Can we turn to Europe and thequestion of the Single European Sky. The SingleEuropean Sky programme aims to create by 2020 anair traYc management system designed, managedand regulated in a harmonised way to sustainEuropean aviation from an air traYc movementpoint of view for the next 30 or 40 years. Thewitnesses we have had before the Committee havealmost uniformly supported the Single EuropeanSky initiative, but some have raised concerns thatthere may be political obstacles. British Airways toldus that the Single European Sky programme needed“full UK backing in order to realize their benefits”,and “ultimately, it is a question of national politicalwill to design and implement cross-border, eYcientairspace integration”. A number of aerospacecompanies also told us that the greatest obstacles tothe Single European Sky were also political. Thisquestion is to the Minister. Given that the Secretaryof State has recently confirmed that the UK remainsa “firm supporter” of the Single European Sky, doesthe Government see any institutional or financialproblems with the UK’s involvement with the SingleEuropean Sky II package or with SESAR?

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Jim Fitzpatrick: We are still committed to both.Clearly, as with any pan-European initiative, thereare going to be obstacles to overcome. However, weare firmly of the opinion that there are benefits whichwill accrue to aviation in the UK and in the world interms of climate change with the ability of countriesto cooperate more fully and therefore aircraft to beable to fly more directly rather than theawkwardness that exists at the moment. I do notthink we are blind to the fact that there arechallenges ahead, but we are committed to theprocess and will continue to do so.

Q543 Mr Hollobone: A key component of the SingleEuropean Sky II proposal is the establishment of aNetwork Management Function whose ultimateresponsibility would be the coordination betweendiVerent Functional Airspace Blocks in Europe andto formalise the existing arrangements for thedesign, allocation and use of airspace. Eurocontrolis likely to perform this role. In its written evidenceto this Committee, Eurocontrol said, “airspaceplanning, design and management and the pre-requisite processes can currently hardly beconsidered as a national, sovereign responsibilityany more”. My question to the Minister is this: doesthe Department guarantee that the proposedNetwork Management Function would not have thepower to overrule national regulatorrecommendations? Secondly, do you agree withEurocontrol that airspace planning, design andmanagement can currently “hardly be considered asnational, sovereign responsibility any more”?Jim Fitzpatrick: We are certainly of the opinion thatit would not compromise us in terms of sovereignty.It would respect national airspace. In relation to theprotections which we have in place, despite the factthat we are positive partners in trying to push thiswhole thing forward as far as we are concerned thosesafeguards are very real and we are very confidentthat we can protect the sovereignty of UK airspace,so we do not see that there is a problem and that wewould have to surrender that.

Q544 Mr Hollobone: Can you guarantee that thepower to overrule national regulatorrecommendations would not be passed to Europe?Jim Fitzpatrick: Mr Hollobone, I cannot guaranteethat I am going to be able to walk out of this roomin half an hour! On the ability to give that cast ironguarantee, as far as we are concerned we see thatthere is no threat to UK sovereignty within theframework that is being established because it iscooperative and that sovereignty is written into thearrangements as they stand at the moment.

Q545 Mr Hollobone: Are you concerned, as I andothers are, that Eurocontrol should have said whatit has said in its written evidence to this Committee?Jim Fitzpatrick: To be perfectly frank, until I heardyou say it 30 seconds ago I had not even consideredit, so to ask me to give an instant judgment as towhy—obviously, Sir Roy has put his hand up and heclearly has a better perspective on this than I have.

Sir Roy McNulty: I do not know all about thatparticular set of words, but I have had manydiscussions with the Head of Eurocontrol, andindeed with the European Commission, and I thinkindeed they were represented in front of you not solong ago. The very clear policy emphasis from themis on partnership and collaboration. It is not a casethat Eurocontrol will dictate how we arrange ouraVairs in this country, but if there are legitimateissues which they think should be raised theycertainly will be raised with us and we will respondto them, hopefully in a spirit of partnership andcollaboration to work out the problems.Sometimes—and I have had a lot of experience ofthis—we have seen words coming from Europewhich maybe sometimes have lost something intranslation or acquired something in translationwhich was not really intended. The arrangements,for Network Management, are very clearly, in mymind, in the mode of collaboration and partnershipand no infringement on things which we wouldregard as vital prerogatives of our regulatorysystem here.

Q546 Mr Hollobone: Yes, but, Sir Roy, sometimesthese words from European institutions come backto bite us in a very severe way decades on..Sir Roy McNulty: Absolutely, which is why we payenormous attention to the legislation, to theimplementing rules, and so on. This, I think, is justfrom a paper, but what I think Mr Hendricks said toyou in his evidence was more clearly of acollaborative and partnership nature than thosewords could be taken to mean.

Q547 Mr Hollobone: Can we move on to the issue ofEASA? The Single European Sky II package alsoincludes the objective of establishing a single safetyframework for Europe, centred on the EuropeanAviation Safety Agency (EASA), in order toimprove safety levels alongside the increase in airtraYc. Are you, Minister, and you, Sir Roy, satisfiedthat the proposed extension of EASA’sresponsibilities to include the safety of air traYcmanagement will not reduce the UK’s high safetystandards and is EASA now running eVectively andat full capacity?Jim Fitzpatrick: I can certainly assure you, MrHollobone, that safety is the Government’s priorityand that we will work closely with the CAA to ensurethat the excellent aviation safety record of the UK isnot compromised. EASA has made considerableimprovements in recent years, in particular in respectof business planning. The first draft business plan forthe next five years has been adopted in December2007 and the financial situation in terms of fees andcharges regulation came in to force in 2007, whichhas stabilised EASA’s budget. The managementboard, on which all Member States are represented,is providing more eVective strategic oversight. Thisis currently being chaired by one of the UKrepresentatives, I understand, from the CAA and theagency has adopted a more consistent constructivepartnership approach with national aviationauthorities such as the CAA. So we do believe that

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EASA has come a considerable way,notwithstanding that they were criticised in the yearsbefore, and we do not believe that there is a problemin terms of safety because, as I have said, we want tomake sure that our record is not in any way, shape orform compromised.Sir Roy McNulty: I am equally satisfied on thatfront. We spend an enormous amount of time andattention studying EASA’s plans and proposals. Wego through them with a fine toothcomb. We debateanything we are uncomfortable with, and to date wehave ended up with regulations we are quite satisfiedwith. As regards air traYc management, the sameprocess has gone around. The initial proposals werenot acceptable to us. We raised many objections.Those objections have been listened to. Theproposition is now in a shape we can live with. Onyour second point, EASA does not yet have thecapacity to fully exercise those functions once theyare in place but there is a European budgetaryprocess to be gone through, which is always a ratherpainful exercise. To date, once they have gonethrough their budgetary processes and they do getthe people they need and the resources in place—andwe are very fortunate to have Michael Smethers asChairman of the Management Board—one of thepriorities we have put on it is making sure that theresources are obtained to do the job properly.

Q548 Sir Peter Soulsby: We have had quite a lot ofevidence about the benefits of fitting the mostsophisticated navigation kits available beyond thestandard which is mandated for airlines. I justwonder whether you can give us a view as to whetherthose benefits are really as great as has beensuggested, and if they are what is preventing theirbeing adopted universally in UK airspace?Sir Roy McNulty: Might I invite Mark Swan tocomment on that?Mr Swan: I assume you are predominantly referringto P-RNAV, Precision Radio Navigation Aids, astep change in capability in that one no longer wouldhave to rely on just ground beaconing in order toincrease your navigational eYciency in any piece ofairspace. On the P-RNAV as a concept in terms ofrisk to delivery of the benefits you have alluded to, Ithink the overall answer is that we simply do notknow yet what the extent of those benefits will be,but theoretically given the end state that could bereached with all aircraft using densely controlledairspace fitted with this type of equipment and thereceiving air fields appropriately configured, one cansee there could be tremendous benefits in the areas ofreducing separation minima between aircraft inallowing improved continuous descent approaches,with the knock-on noise and environmental eVects.But of course all of this has to be taken inside theframework of the safety network which wouldmanage this increase in navigation eYciency andthat is where the risk has to be mitigated mostcarefully in the already existing control proceduresthat we have. I think the other point I would oVer isthat of course in terms of UK airspace we do notcontrol what other European companies and other

European countries either have fitted or have trainedat this point, although the overall Europeanaspiration for P-RNAV is still there as a concept.

Q549 Sir Peter Soulsby: So what do you see as thesteps that are necessary to assess the benefits and thetimeframe for doing it?Mr Swan: Some steps are already in place. I think theUK has had the initiative in terms of from the CAAperspective NATS was instructed some time ago interms of all future airspace design to include P-RNAV capability within that airspace change andthere has been the odd trial of P-RNAV routes,notably Arlanda in Sweden, but of course thatairspace is not nearly as congested as the LondonTMA. There are some trials but as yet the risk todelivery of the final benefits I think will be a crawl,walk, run, type of concept with careful evaluationbased on the safety appraisal of just how good thesenavigational techniques are and what that will meanin real terms for improving eYciency.

Q550 Sir Peter Soulsby: What do you think is arealistic timeframe for looking to theimplementation of some of these benefits?Mr Swan: It is very diYcult for me to judge. I do nothave the background expertise to really quantify it.I would say in the order of years, though, in order tounderstand the eYciency benefits to be derived andbuilding on the current initiatives one could imaginein, let us say, for example, something like a five yearperiod when your careful airspace design processstarts to take place, then you would be able to reallyassimilate the benefits this could bring. Due to thesafety case and the complexity of the airspace we aretalking about, it really is a walk, crawl, run, but Ithink the European aspiration we fully support.

Q551 Sir Peter Soulsby: Does the Department seethat as a realistic timeframe?Mr Moor: Yes, I think we do. I think this is anessential part of where SESAR and other Europeaninitiatives can add some real value to having anapproach across Europe which is mutually agreed,which will ultimately end up in significant reductionsnot only in time delays but also potentiallyreductions in CO2 emissions as well. I think thetechnology behind P-RNAV and other initiatives isquite essential in terms of getting the benefits whichwe are hoping from the Single European Sky.

Q552 Chairman: How does the Department’sguidance to the CAA protect general aviation frombeing squeezed into smaller areas? Does theDepartment give any guidance to try to achieve that?Mr Moor: We recognise the value general aviationcontributes to the economy, but one of the issueshere is that it will always be a balance between thetwo and I think, as Sir Roy said earlier, this 60%/40%between controlled airspace and uncontrolledairspace is not a given percentage, it is a balance tobe achieved. We recognise the value of generalaviation, but we also recognise the value ofexpanding commercial aviation and civil aviation, soI think it is very important that we maintain that

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balance. I am not sure we need to give any moreguidance, but perhaps Sir Roy has a view on thatas well.Sir Roy McNulty: I do not feel there is any need formore guidance, but that is a position I am usually in!I do not think it is as serious a squeeze as issometimes portrayed. We did a calculation recentlyon the change between controlled and uncontrolledairspace and uncontrolled airspace has reduced bysomething like 2% over the last five years andcompared with other kinds of squeezes one can thinkof, that is not very extreme. What I think is more ofan issue for general aviation is access to airfields.There have been pressures at large busy airports tohike their charges and general aviation is beingsqueezed out of those for commercial reasons. Therehave been smaller airfields acquired for housing orother purposes and built on and so are no longeravailable to general aviation. In my mind that is abigger issue than airspace issues.

Q553 Chairman: Whose responsibility would it be toaddress that?Sir Roy McNulty: We did a strategic review ofgeneral aviation three or four years ago. It was anissue which was flagged up. The Department, Ithink, agreed to discuss that with DCLG andwhoever else is involved from a planning point ofview. I think it is certainly, in my mind, more aGovernment policy issue.

Q554 Chairman: Is that something the Departmenthas discussed with DCLG?Mr Moor: I think this comes back ultimately tooverall capacity constraints we have across theaviation sector and I am afraid a lot of this is aknock-on implication, so when you have an airportlike Heathrow, which is operating at 99%, traYcwhich would have gone there moves to anotherairport, and it goes down the chain, so you end upwith airports like Biggin Hill being used much morenow for business aviation because they have beensqueezed out of other airports within the CentralLondon area. So I think the issue here ultimatelycomes down to the need for more capacity across thewhole of the South East airspace, but I think we alsohave to bear in mind that there are quiteconsiderable issues at a local level with smallairports and noise and regularly we receive lettersfrom airports complaining about noiseconsiderations. Our view is that our Air TransportWhite Paper looks at it at a national level, atnationally significant airports, and therefore CLG isexpected to give planning guidance around theapplication of local airports. But again, even at alocal level there is always this balance between noise,pollution and the local economy and the benefitsaviation brings to it.

Q555 Chairman: But have you been aware of this asa specific issue? One of the points Sir Roy has justmade is about diVerent land use. Is that somethingyou have been aware of?

Mr Moor: We have regular conversations with CLGabout planning land use and there is a number ofproposals even at this moment about changingairports into diVerent alternative use and that issomething which from an aviation perspective wehave concerns about and those are conversations wehave had with CLG, but there is an awful lot ofairports in the UK and it is quite diYcult to assesshow that land use should be used most eVectively inthe regional areas. I think that is why we feel it isappropriate for local planning authorities to makethose decisions rather than bringing it to a nationallevel.

Q556 Mr Martlew: Just on that point, we are notmaking any more airports, are we? The danger isthat we have got existing airports and a lot of themare in the wrong place because they were there for theWar, but you are not going to open any new airportsand the more you lose, the less capacity you haveunless you add extra strips? Is that not a fact? If moreairports go out of business, then you are going tohave more capacity problems?Mr Moor: In terms of civil aviation, this is what welooked at in the Air Transport White Paper and backin 2002 we looked at over 400 diVerent potentialschemes for expansion, many of them small airportswhich had an aspiration to expand. Our decision atthat stage was to allow the expansion of existingairports because we felt that was sustainable growth,rather than going to a small airport and changingthat into a much larger airport. We believe the AirTransport White Paper is a sensible approach to theoverall civil aviation need. We do recognise, though,that there is a growing demand for general aviationand business aviation. There is capacity around thecountry for that, but in order to deal with that youhave to balance the diVerences between the noise andthat growing demand.

Q557 Mr Leech: I am not sure whether you haveanswered this question already, but is theDepartment or the CAA a statutory consultee inplanning applications to convert airports tosomething else?Mr Moor: It is not from the Department’sperspective, but the CAA —Sir Roy McNulty: I do not think so, but I can check.

Q558 Mr Leech: Is there not a case, though, that if adecision made by a local authority may have a long-term impact on the aviation industry because youare getting rid of a small airfield, then surely theDepartment or the CAA should be a statutoryconsultee? Do you not agree with that?Mr Moor: What I would say is that we obviouslywould be a consultee on any of the strategic airportswe set out in the Air Transport White Paper. Thoseare the airports we decided were nationallyimportant and therefore the airports we took a viewon, and we then did a progress report and for the topairports we have asked them to do master plans aswell.

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Q559 Mr Leech: But from the perspective of generalaviation and business aviation, if they are beingconstantly squeezed out of the bigger airports andthese smaller airports are becoming more importantfor general aviation, surely in those circumstancesthe smaller airports then should take on a highersignificance than they have in the past?Mr Moor: I just come back to the Air TransportWhite Paper and even in the White Paper we lookedat quite an amount of smaller airports. I think ourview here is that what is happening in smallerairports is that often business aviation is squeezingout general aviation because it is more valuable tothe airport itself. So if you go to Biggin Hill, you cansee a very clear indication there that businessaviation is taking a much greater proportion of theirair traYc movements in comparison with generalaviation. That does not mean to say that generalaviation has not gone somewhere else or cannot stilloperate from Biggin Hill. When you go to see thesesmall airports, I do not believe they have a hugecapacity overall problem because certainly BigginHill is an active marketer in terms of getting morebusinesses to operate out of that airport.

Q560 Chairman: Minister, is this something whichhas been drawn to your attention as a policy issue?Jim Fitzpatrick: Planning disputes or planningapplications with the CLG—I am aware of severalwhich have gone through the process. One inparticular comes to mind where the airport waspartly owned by the Maritime and CoastguardAgency and Hampshire Constabulary and there wasa dispute between them and GA, so I know theseissues are around, but in terms of a formal role as aconsultee—forgive me, I would have to check therecords, Chairman, but I do not rememberexpressing a formal opinion other than just to beaware, because it concerns general aviation, thatthese issues at smaller airports were happening, andcertainly when I meet representatives of GA they doarticulate a concern that there is a squeeze, but Ithink, as we have said, it is more in the perceptionand more in the change of pressures fromcommercial operators than anything else.Ms Smith: The British Business and GeneralAviation Association suggests that economic valuesshould be at the heart of every UK aviation policydecision and they have said that it seemsanachronistic that a scheduled carrier laden withparty-goers destined for a cheap weekend in Pragueshould have the legal right to displace traYc of fargreater net worth to the British economy. This wassomething they brought up when they came to giveevidence. Does the DfT believe that this concept ofrationing or planning for use of air space accordingto the economic worth of the flight has anycredibility?

Q561 Chairman: Minister, is this a policy youmight pursue?Jim Fitzpatrick: Given the pressures on generalaviation, I think there are going to be conflictinginterests and we would obviously want to make surethat general aviation had its place. If there are

decisions being made at a local level that one flightshould have priority over another, then that wouldbe a local matter. Forgive me, I am not familiar withwhat the national regulations say in terms ofwhether we have a role in determining which aircrafttakes oV as opposed to another.Mr Moor: If I could just add to that, it is acompetitive marketplace and we do not run airportsat the end of the day. General aviation, we recognise,contributes significantly to the UK economy andtherefore there are airports in the South East as wellas around the country which provide a service togeneral aviation and to business aviation. In terms ofrationing slots, if I take an example, City Airportdoes have business aviation flying in and out of it.They have been squeezed recently and that is acommercial matter because they can make moremoney by selling a slot to a commercial providerthan to a business aviation provider. However, if thatslot is really valuable to that business aviationprovider, I am sure they can also pay.

Q562 Ms Smith: London City Airport itself hasactually said that some form of organised priorityaction based on the economic significance ofpassengers might be a good idea, but would the viewbe in the DfT as well that there is a potentialenvironmental impact from following such a courseof action which would be detrimental to the UKgenerally? In other words, if you give priority tosmaller aircraft with fewer numbers of passengers onboard, that in itself would be environmentallydamaging?Jim Fitzpatrick: We have outlined in broader strokesour concern about the environmental impact ofaviation and set out how we would want to see itprogressing in general terms. The question of the sizeof aircraft and the capacity of aircraft and whetherthey are flying with fewer passengers is an entirelyseparate issue and we have actually madepronouncements in respect of the ability of slots tobe protected at the moment because of the economicdownturn, not to be lost to airlines as a result of theirnot being able to use them, and a temporary measureover the summer months. Forgive me, City Airportis in my constituency, I should probably say,Chairman, because I am a big supporter. Theyemploy quite a lot of people and are very proactivein the community, so I understand the pressures theyare under, as outlined by Jonathan, but they areworking in a commercial environment, as are othersmall airports, and therefore they will look tomaximise their revenue to make sure they are able tofunction. City Airport is probably better placedbecause it is a successful airport, despite catering forboth commercial and general as well as privateflights. With the smaller airfields, again they havethese conflicting issues which they have to deal with.I am not sure the environmental dimensions wouldbe a major concern for the Department because wehave laid out how we want aviation to contribute todealing with climate change in making itscontribution to reducing emissions in overall terms.

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Q563 Ms Smith: Would it be possible to objectivelymeasure the diVerent economic significance ofdiVerent flights? Would that be possible?Jim Fitzpatrick: It is clearly possible to determinethe benefits of an A380 and the new technology of abrand new aircraft and its ability to fly with doublethe payloads of most other commercial aircraft andbe quieter, cheaper and cleaner against olderaircraft. I think the simple answer is thattechnologically it is possible to determine the carbonfootprint of any engine.Ms Smith: I meant the economic significance of thepassengers.

Q564 Chairman: Would it be possible to measure theeconomic value of the passengers? The proposal putto us was that priority should be given to aircraft orair passengers depending on their economic value,presumably to the country. Would it be possible todiVerentiate between the diVerent aircraft?Jim Fitzpatrick: I think you are at risk of entering into the realm of individual privacy and the right to theindividual to function. If somebody is coming on aprivate jet into City Airport going to Canary Wharf,they could be bringing in a contract worth £100million to the UK economy. Equally, they could becoming in for a weekend to do shopping in OxfordStreet. It is the same as somebody who is travellingon a commercial jet, who may be bringing in a bigcontract or coming for a weekend shoppingexpedition. To actually ask people to declare—well,we do ask, “What is the purpose of your visit?” to acertain extent, but when we screen them to make surethey are not a security risk, or whatever, I am notsure—maybe I am entirely wrong here, Chairman.Maybe we are screening everybody to work out whowe want to come into the country and who we donot want!

Q565 Chairman: Are we going to have somerevelations now? I will ask Sir Roy if he wants tocome in on this.Sir Roy McNulty: I personally would view that as avery impractical suggestion. I think the job of thecontrollers is diYcult enough dealing with all thefactors they already address without looking at theprice tag on the side of each aircraft to decide whatpriority it should have. I might add that at the timeof the NATS PPP an idea which surfaced fromsomewhere, not from NATS, was that priorityshould be given to airlines who were prepared to payfor priority and that was scotched firmly by theaviation minister at the time, and rightly so. I do notthink there is any place within the job of air traYccontrol for commercial priority expressed in thoseterms.Mr Moor: If I could just say something briefly, Ithink the key issue here is what market failure areyou trying to regulate for, and I think in this instancethere does not seem to me to be a market failurearound who should use slots. As soon as you get intothat environment and start to regulate about whocan use slots and who cannot use slots, you will startto actually have perverse market conditions wherethe airports will say, “You are holding a slot back for

somebody and that’s not commercially viable forus.” So my question back to City Airport would be,“What market failure do you want us to correctfor?” It is a competitive environment.

Q566 Mr Martlew: I represent an area which has avery small sub-regional airport, but it used to have aregular flight into Heathrow and it was importantfor the economy of that particular sub-region. Ifthere is no priority given to anywhere, and bearingin mind the major London airports have a nationalpriority, surely there should be somebody whodecides that you can fly in from one of the smallerairports, if you want to put a scheduled flight on,that they have priority over the people going to thestag night in Prague because the economic benefitsto that sub-region are very important.Jim Fitzpatrick: I think that is absolutely fair andabsolutely right, and indeed it is one of the issues weregularly consider, and indeed are considering at themoment. I have recently had representations fromDurham Tees Valley, because BMI have withdrawntheir flight, they want to use the slot at Heathrow forsomething else. They are saying that actually has aneconomic impact on their sub-region within theNorth East. We have had representations previouslyfrom Inverness and from other parliamentarycolleagues from diVerent parts of the country whosay that the economic regulation should considerregional and sub-regional development as a higherpriority than it does at the moment. That is a movingfeast because that is a matter which will have to beconsidered and applied each and every time, and it isa matter which is under consideration by theDepartment at present.

Q567 Chairman: Is there anything in today’s Budgetwhich could impact on the CAA’s work in relationto safety or environmental resources?Jim Fitzpatrick: I am not sure whether we have hadan opportunity, Chairman, to make an assessment ofthe Budget. Forgive me, I am looking to mycolleagues. I do not know whether Sir Roy has hada chance to —Sir Roy McNulty: I have been busy with theDepartment all day and I thankfully know nothingabout the Budget!

Q568 Chairman: Are you aware of anything therewhich could impact upon the resources in relation tosafety or the environment?Jim Fitzpatrick: Obviously, there is bound to besomething within the Budget but I have not had achance to study it yet. By virtue of the Government’scommitment to public expenditure and trying tobuild and grow the UK’s way out of a recession andTransport being the Department that it is in all itsaspects, not just aviation, a big player in terms ofinvestment in public infrastructure, I would be verysurprised if there was not something there. In respectof whether there is something specifically dealingwith aviation, I would have to check with colleaguesand write to the Committee in due course.

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Q569 Chairman: Could we have any guarantee thatthe budgets in relation to aviation safety andenvironmental issues would be protected?Jim Fitzpatrick: I think you can certainly have aguarantee, Chairman, that safety is the top priorityfor the Government in respect of aviation, as it is inshipping, as it is in road safety. With aviation clearlyit is and we are very clearly on the record, as are allof our partners and stakeholders, in regarding safetyas a top priority. In terms of the environment, I thinkduring the course of the last 90 minutes or so we haveclearly outlined that this is something which is underconsideration. We are reviewing the position at themoment and we will be publishing later in the year.It was part of the planning inquiry, so theenvironment is something which is going to bepronounced on later and is something which ismoving. As we have developed environmental policyto deal with climate change, the whole ofGovernment is looking at its role and itsperformance set against the targets which we haveagreed for Government in the years ahead.

Q570 Chairman: There is a long and expensiveconversion process for military air traYc controllersmoving into civil work. Do you think there is anyreason to have a major review of that process, tospeed it up or to make it more eYcient?Jim Fitzpatrick: I am sorry, Chairman, I am notqualified to say anything on that.Sir Roy McNulty: I can maybe add a brief comment,which may need a more detailed note in due course.The jobs which civil air traYc controllers andmilitary aircraft controllers do are fairly diVerent, sothey are trained diVerently to do diVerent types ofjobs. It therefore is not the case that an ex-militarycontroller falls easily into a civil job to perform thatkind of task in an eYcient way. We do make someallowance. I believe there is some reduction in termsof the training requirement, but it is not a majorreduction. We would be quite happy, if theCommittee wished, to do a review of that, but I amnot sure it is an avenue where there is an easy quickwin at the end of it.

Q571 Chairman: You are not aware of changeswhich could be made?Sir Roy McNulty: We can look at what changescould be made, but this has been looked at beforeand the conclusion basically was that they comefrom diVerent backgrounds with diVerent skills,doing diVerent tasks before, and to make sure theyare absolutely as proficient as we need for civil airtraYc controllers they need substantial training. Wedo not do that for fun. It costs NATS money and itis not done just because that is the way it has alwaysbeen done.

Q572 Sir Peter Soulsby: There is some evidence, Ithink, from the airport operators who were drawingour attention to the predicted shortage of qualifiedcontrollers in the future. First of all, are they rightthat there is likely to be a shortage, and if this is notthe solution, what is?

Sir Roy McNulty: I think traditionally there hasbeen a shortage and I agree with the comments theMinister made earlier. There is likely to be aresumption of traYc growth and then there will be aneed for more controllers. When I was in NATS wewere facing one of our periodic binds in this respectand we looked at every conceivable avenue toquicken up the supply of capable controllers. Welooked at the military aspect at that time and therewas no easy solution available to us because, as wekeep on saying in many contexts, safety isparamount and we will not put diluted skills intodoing a job like this.

Q573 Sir Peter Soulsby: Is it likely to be aparticularly serious problem in the near future?Sir Roy McNulty: In the near future, no. To anextent, on this particular topic we get a benefit fromthe recession, so the pressures which constantlyincreasing traYc have put on the system are easedand will be probably for the next two or three years,but long-term the need to attract and train qualifiedcontrollers will remain a challenge. In the very long-term the job will change if SESAR is brought in andis successful, but you will still need controllers,probably trained to an even higher level withdiVerent skills, higher levels of skills.Mr Swan: If I may add, I think we, the UK, aresigned up to a common core training requirementharmonised with the rest of Europe’s civilian airtraYc controllers and the military is not. As Sir Royhas said, their training requirements are diVerent.For the military to then adapt that common coretraining requirement, I suspect—you would have toask them—would probably cost a considerableamount of money, an investment for skills thatwould not have to be used until they became civiliansthemselves, if that is the career they chose to pursue.So that harmonisation versus the financial trade-oVI think is probably a key consideration were you toask the MoD for its view.

Q574 Chairman: Minister, I would like to ask youabout the planning process, the planning system.Are you satisfied that the guidelines in place aboutthe parallel operation of the work of theInfrastructure Planning Commission on airportdevelopment and the related responsibility of theCAA under the Airspace Change Process aresuYciently clear?Jim Fitzpatrick: I think we covered a lot of thisearlier on, Chairman, when we were discussing theAirspace Change Process and how long it takescompared with the planning process for, forexample, Heathrow and how we made theconsideration before having consulted with NATSand it will have to be finalised afterwards once theplanning application is in. The Planning Act whichprovides the new arrangements for nationalinfrastructure projects is a lot clearer and a lot morestreamlined than that which went before. We areconfident that we can work within the process, andindeed in terms of the update of the Aviation WhitePaper it is quite clear that when we said we wouldreview and progress publication every three to five

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years—and we are committed to a national policystatement on aviation which will fit into the nationalplanning process—that looks to be the way forwardin due course, where we are likely to be publishingour next review.

Q575 Chairman: Sir Roy, do you have any viewson that?Sir Roy McNulty: I think they are obviouslyconnected subjects, but I have always seen theAirspace Change Process as somewhat following on

from the planning process. The example I gaveearlier was Manchester. The second runway atManchester took four or five years in thedevelopment and getting planning approval. Onceplanning approval was obtained, the necessaryairspace changes were made within a couple of years,which was about half of the construction period, sothe two processes fitted together quite well, and thatis the norm.Chairman: Thank you very much for coming andanswering our questions.

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Written evidenceMemorandum from the Campaign for National Parks (CNP) (AIR 01)

The Campaign for National Parks (CNP) is the national charity which campaigns to protect and promoteNational Parks for the benefit and quiet enjoyment of all. We welcome the Committee’s inquiry into the useof airspace and are pleased to have this opportunity to submit evidence.

2. Of the Committee’s stated areas of interest, this submission relates to changes to airspace managementthat we believe are required as a result of the impact of increased airport capacity on National Parks.

Summary

3. Our main concerns about current and future projected capacity and use of airspace relate to theincreased risk of noise and disturbance to National Parks, where peace, tranquillity and a sense of escapefrom day-to-day pressures are highly valued and defined as one of the special qualities for which these areasare designated in the first place.

4. We have set out below some brief background on National Parks and how they are reflected in aviationpolicy, by way of context to the comments that follow.

Background—National Parks

National Park purposes

5. National Parks in England and Wales have two statutory purposes:1

(i) to conserve and enhance the natural beauty, wildlife and cultural heritage of the NationalParks; and

(ii) to promote opportunities for the public understanding and enjoyment of the special qualities ofthe Parks.

6. A wide range of public bodies, including the Department for Transport (DfT) and the Civil AviationAuthority (CAA), must take these purposes into consideration when making decisions that could aVect theNational Parks.2

National Parks and aviation policy

7. The Transport Act 2000 requires the CAA to carry out its air navigation functions in the manner itthinks best calculated to, among other things, take account of any guidance on environmental objectivesissued by the Secretary of State.3

8. Directions issued under the Act also state that in relation to the environmental impacts of airoperations, the CAA must take into account:

(i) guidance given by the Secretary of State on the Government’s policies on sustainable developmentand on reducing, controlling and mitigating the impacts of civil aviation on the environment;

(ii) the need to reduce, control and mitigate as far as possible the environmental impacts of civilaircraft operations and in particular the annoyance and disturbance caused to the general publicarising from aircraft noise and vibration, and emissions from aircraft engines; and

(iii) The need for environmental impacts to be considered from the earliest stages of planning.4

9. Guidance issued by the Secretary of State states that changes to airspace arrangements should be madeafter consultation, only where it is clear that an overall environmental benefit will accrue or where airspacemanagement considerations and the overriding need for safety allow for no practical alternative [emphasisadded].5

10. With regard specifically to the over-flight of National Parks and Areas of Outstanding Natural Beauty(AONBs) the Guidance states that while legislation and planning policy do not preclude over-flight of theseareas and government policy will continue to focus on minimising over-flight of more densely populatedareas below 2000ft, where it is possible to avoid over-flight of National Parks and AONBs below this altitudewithout adding to environmental burdens on more densely populated areas, it clearly makes sense to doso.6

1 As set out in section 5 of the National Parks and Access to the Countryside Act 1949, as amended by section 61 of theEnvironment Act 1995.

2 Section 11A(2) of the 1949 Act as amended by section 62(2) of the Environment Act 1995.3 Section 70(2).4 The Civil Aviation Authority (Air Navigation) Directions 2001, incorporating Variation Direction 2004.5 Guidance to the Civil Aviation Authority on Environmental Objectives relating to the exercise of its Air Navigation Functions

(2002), paragraph 36).6 As above, para 45.

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11. Recognising the general policy aim to protect the special qualities which make the countrysideattractive and special, including tranquility, and the specific aim to give strong protection to nationallydesignated landscapes such as National Parks AONBs, the Guidance also states that whenever practicablethe CAA Director of Airspace Policy should pursue policies that will help to preserve the tranquility of thecountryside where this does not increase significantly the environmental burdens on congested areas.7

Inquiry Questions

Is the current approach to planning and regulating the use of UK airspace adequate?

How are the eVects of aircraft noise and emissions taken into account when changes are made to the use ofairspace? Who should be consulted? How should the balance between conflicting interests be struck?

12. We are taking the questions above together because in the present context the issues of regulatoryadequacy, aircraft noise, and the weight that should be given to competing environmental factors as wellas non-environmental factors are connected—we believe that the current approach to regulating the use ofairspace is inadequate insofar as it purports to protect National Parks from aircraft noise and disturbance.

13. How the eVects of aircraft noise and emissions are taken into account in decisions relating to airspaceis set out in the background section above.

14. The inadequacy of the current regulatory framework has most recently been demonstrated in theendorsement by the CAA of proposals to extend the area of controlled airspace over parts of the New ForestNational Park (the Terminal Control South West, or TCSW decision). This decision threatens to seriouslydisturb the peace and tranquillity of the National Park.

15. CNP, together with the New Forest National Park Authority and a strong body of respondents,expressed serious concern about the way in which the TCSW decision was taken, as well as the outcome, tothe DfT. In particular, we questioned the evidence base underpinning the CAA’s decision and believe thatin making it, insuYcient weight was given by the CAA to the impact of the proposals on tranquillity withinthe National Park. Our concern was only heightened by the fact that the DfT Guidance on environmentalobjectives referred to above, which the CAA is specifically required to take into account, could be interpretedby the regulator in such a way as to allow it to reach this decision.

16. In this context CNP has welcomed the publication of Sir Joseph Pilling’s report of his independentstrategic review of the CAA, which makes a number of recommendations relating to the CAA’senvironmental responsibilities. We have written to the Secretary of State for Transport strongly to urge herto accept the key environmental recommendations, in particular that:

(i) the CAA should have a general statutory duty in relation to the environment;

(ii) the Secretary of State should provide a framework which oVers guidance to the CAA on how toreconcile environmental and other competing considerations; and

(iii) the DfT’s guidance on environmental objectives in relation to the CAA’s air navigation functionsshould be reviewed to ensure that it continues to be up to date.

17. In our view (ii) and (iii) link closely to the present inquiry’s questions concerning the adequacy of thecurrent airspace regulatory framework and our comments to the Secretary of State are thereforesummarised below.

18. CNP would strongly support the Government taking measures to strengthen the alignment ofaviation policy with wider government environmental policy through the DfT Guidance. In particular, webelieve that it should be strengthened to properly reflect the Government’s position on nationally designatedlandscapes. At present, while the Guidance seeks to acknowledge the special status of National Parks (seeparas 45 and 46, cited above), we believe that it does not go far enough to give real meaning to the specialstatus conferred on these areas by law, or to the statutory duty that binds the CAA and others to have regardto National Park purposes when making decisions that could aVect them.

19. In relation to the duty, Planning Policy Statement (PPS) 7 states that:

. . . National Parks have been confirmed by the Government as having the highest status ofprotection in relation to landscape and scenic beauty.”8 [emphasis added]

Defra guidance on the duty states that it is “particularly important to the delivery of the purposes ofprotected areas and to the overall achievement of sustainable development in rural areas.”9 The guidancegoes on to make clear that while the duty does not override other obligations or considerations which haveto be taken into account by public decision-making bodies, it is intended to ensure that the purposes forwhich National Parks have been designated are recognised as an essential consideration in reachingdecisions or undertaking activities that have an impact on them.

7 As above, para 46.8 Planning Policy Statement 7: Sustainable Development in Rural Areas, paragraph 21.9 Duties on relevant authorities to have regard to the purposes of National Parks, Areas of Outstanding Natural Beauty

(AONBs) and the Norfolk and SuVolk Broads.

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20. We believe that the TCSW decision provides evidence that the current regulatory framework for theuse of airspace is inadequate to protect National Parks in the way envisaged by the statutory protectionaVorded to them elsewhere. Other aspects of the Guidance, such as how diVerent environmentalconsiderations are weighed up and the circumstances in which decisions must be referred to the Secretaryof State, would also benefit from review. While the TCSW decision raised doubt as to whether the DfTGuidance as it stands was properly followed, we believe that it also highlighted the need for a freshassessment of the Guidance itself in order to ensure that it provides adequate protection for all nationallydesignated landscapes, especially National Parks, in accordance with wider government policy.

21. Sir Joseph Pilling’s report provides a timely opportunity for the current policy shortcomings to beaddressed and we would ask the Committee to join us in urging the Government to look favourably uponits recommendations.

22. National Parks represent some of the most peaceful and tranquil areas of England and Wales. Thevalue that we as a nation ascribe to such qualities will only increase in coming years as the development ofurban areas continues to grow and everyday life becomes generally more cluttered with noise and stress oftenattributable to transport. In this context it is critical that the protection of National Parks and othernationally designated landscapes is given the highest priority in all government policy that has the potentialto have a negative impact on their special qualities, but especially in areas such as aviation expansion thatpose a direct threat.

September 2008

Memorandum from Mike Andrews and John Sargent (AIR 02)

Airspace Change Proposal—West Suffolk

I am writing to you as a resident, for 16 years, of an area renowned for its beauty and also recognised onthe CPRE Tranquility Map as an extremely quiet area. I believe that these facts have contributed to the verylucrative horse industry being centered on Newmarket and its environs.

When low flying planes pass overhead, which they do from time to time, the noise level is unbelievableand the animals suVer accordingly. This is not good for the well-being of the animals—or the local residentscome to that—and I can see the horse racing owners and breeders moving their studs elsewhere which willaVect the finances of the area also the job and trade economy.

Any area as tranquil as Wickhambrook will be extremely aware of the noise levels created by the low flyingplanes on the stack and exit route. Especially as low as 7,000–4,000 feet as the planes make their finalapproach to Stansted. I fail to understand why the North Sea cannot be considered as a holding area, wherefew people would be disturbed. Also the value of property in this area will be greatly diminished.

I therefore recommend that the new planned route be reconsidered taking into account the impact on thetranquilly of this area and the eVect it will have on the local equine, wildlife and other animals apart fromhumans, not to mention the tourist industry.

Please register my strong objections to the new Airspace proposals.

September 2008

Memorandum from Little Thurlow Parish Council (AIR 03)

Ref: NATS Proposals for a New Flight Stack for Stansted Western Approach

We would like to comment on the current proposals, as invited. This is a short submission but we havealso provided a bullet-point summary, as requested.

Summary

— Reasons not to disturb rural areas of outstanding beauty and tranquillity.

— Possibilities of using sea areas for stacking.

— Reasons not to ‘share the problem’ uniformly.

— More fundamental questions of technology and operational practice.

— Need for a comprehensive international review.

— Duty of government to think ahead and if necessary radically.

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Submission

1. The village and area in which we live is at present relatively undisturbed, but the new proposals willradically aVect that, with a dramatic eVect on our quality of life. We are not alone in this, hence we do notsimply suggest that the problem be moved elsewhere to another equally beautiful rural area.

2. One obvious place where it could be moved, however, is over the sea. Stansted is after all only 35-40miles from the coast, or approximately 10 minutes flying time, so the schedules would not be seriouslyaVected by that, given that journeys are in any case going to be delayed by stacking anywhere, and usuallyfor periods longer than 10 minutes.

3. One might also argue that if stacking over land is thought to be unavoidable it would be better to stackover areas already aVected by aircraft noise. “Spreading the problem” may sound fairer but the logicalconclusion of that line of argument is that all parts of the country should be adversely aVected. One can seewhy that is a bad argument if you apply it to other environmental and conservation issues. The Governmentin other contexts rightly designates certain areas as protected or conservation areas freed from all kinds ofurban and industrial development, and it should do the same in this area. “Noise pollution” is a very realform of pollution.

4. But the more fundamental consideration of all is why it is necessary to stack at all in this way? Withmodern technology there should be no reason why flight times cannot be adjusted so that arrival times canbe synchronised without the necessity to stack over land. A large proportion of the routes for Stansted arein any case from Europe and that gives the opportunity for adjustments over the sea (including a completeturn if necessary) before anyone on the ground is inconvenienced.

5. Is it not time for a complete and radical review of all the Government’s policies in this area nationwide,and indeed with our partners in Europe and North America? This is a growing problem and all the forecastsare that despite temporary setbacks air traYc will go on increasing. We have gone far past the point whereit makes sense to implement local and piecemeal solutions. We should now be aiming for a far-sighted andcomprehensive set of policies which demand new technological and social solutions to what can only becomemore pressing global problems.

Thank you for your attention to this submission.

September 2008

Memorandum from Redhill Aerodrome Limited (RAL) (AIR 04)

Please note that RAL has addressed itself only to Questions 1, 3, 6, 7 and 8 from the list of the 11 questionsin the call for written evidence.

1. Summary of Arguments

1.1 RAL believes that the Government should rely on the White Paper forecast in terms of passengernumbers in relation to long term growth, but are concerned that the substantial change in traYc distributionarising from the growth in low cost carriers has not been taken into account in terms of provision of runwaycapacity, particularly at Gatwick. (Q1)

1.2 RAL has little confidence that NATS will become pro-active. It believes that an Airspace Master Planthrough to 2030 is desirable, but that in practice a piecemeal approach will probably need to be adopted.Otherwise, any Master Plan would need to allow for airport developments not currently foreseen to beincorporated at a later stage. (Q3)

1.3 NATS future airspace design needs to take into account planned technical developments in Europe,particularly in relation to the Single European Sky. (Q6)

1.4 RAL is suspicious of the close relationship between NATS and BAA, which possibly aVects adverselyplans put forward by other airports. (Q7)

1.5 RAL believes that airspace considerations unnecessarily delay the planning process, whileunsubstantiated negative assessments are permitted to damn “unfavoured” plans. (Q8)

2. Background

2.1 Redhill Aerodrome Limited (RAL) is the owner and operator of Redhill Aerodrome in Surrey.Although currently a general aviation airfield with two grass runways, members of the House of CommonsTransport Committee may be aware that RAL has long sought to convert it to a single surfaced runway of2,000 metres and operate it as a reliever second runway for Gatwick Airport.

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2.2 RAL has been frustrated by BAA’s lack of vision for Gatwick, and its inability to understand howthe presence of a reliever runway could significantly improve the profitability of their own facility. Insteadit has favoured development at distant Stansted. This is perhaps a function of BAA’s dominance of Londonand South East airport capacity.

2.3 RAL gave verbal evidence to the Committee on May 7th 2003 in connection with its report onAviation (HC454-I, July 2003). In the Committee’s Conclusions, paragraph 259 of the Report stated that:

“It could take as long as 15 years to build any new runway (in the South East). This would fail toaddress the very real problems that exist today. Constrained capacity at Heathrow and Gatwick willlead to further reductions in regional access to London airports. There are a range of measures,particularly feeder-reliever airports that would provide for more immediate availability of runwaycapacity at or in close proximity to the airports where the demand is greatest. We strongly recommendthe establishment of such an airport. Its most important function would be to act as ‘London’s regionalairport’”.

2.4 Two possible locations for such an airport were considered—Redhill and Northolt, but in thefollowing paragraph, the Report noted that:

“A third runway at Heathrow would entail the closure of Northolt . . The Government must urgentlyconsider whether an extended and re-aligned runway at Northolt would provide an increase in capacitymore quickly and with lower environmental impacts than a third runway at Heathrow”.

2.5 Finally, in paragraph 264, the Committee noted that:

Any development will have environmental impacts. We believe those impacts will be minimised by:

— making best use of existing facilities (as recognised by the subsequent Future of Aviation WhitePaper);

— expanding existing airports on a case by case basis; and

— dismissing the construction of new major airports on Greenfield sites.

2.6 RAL is in total agreement with these conclusions. Redhill is an existing facility which is underused,while the existing runway at Gatwick could be far better used by larger intercontinental aircraft.

2.7 Similar conclusions were reached by an earlier Select Committee Report in 1998. This report onRegional Air Services (Report 589-I, July 1998) concluded (paragraph 120) that further studies should bemade on both Northolt and Redhill, even though “a planning application to create a feeder airport (atRedhill) was rejected by the last Government”.

2.8 A full presentation was made to the Department for Transport in 2003 as part of its pre-White Paperstudies. The rejection of the proposal can be seen in paragraphs 11.117 to 11.119 of the White Paper (Cm6046, December 2003). There is a suspicion that, at an earlier stage, drafts of the White Paper included arecommendation for a new runway at Redhill, but that pressure was brought to bear on the DfT to alterthat conclusion.

2.9 The main reasons given for rejection of the plans to construct a reliever airport at Redhill (includingthe planning application) were concerned with airspace availability, which is why RAL is anxious to shareits views on the current approach to airspace taken by NATS, the CAA and the Department for Transport.

2.10 For the benefit of the members of the Committee, the features and benefits of an expanded RedhillAirport can be summarised as follows:

(a) A single 2,000 metre runway capable of handling all domestic and European flights (but notintercontinental flights) within five years.

(b) The runway would be four miles north-north-east of Gatwick’s current runway, and parallel to it,minimising any chance of airspace conflict.

(c) The airport would have its own passenger terminal capable of handling 200,000 flights and 20million passengers annually (compared to 250,000 flights and 30-40 million passengers atGatwick).

(d) The passenger terminal would be linked to the existing Gatwick terminals by a dedicated rapidtransit line adjacent to the existing London to Gatwick rail line at the western end of the runway.The journeys would take some six minutes, (compared to three minutes between Gatwick Southand North Terminals and faster than today’s transfers between the various terminals atHeathrow).

(e) The passenger terminal would also be linked to the adjacent M23 motorway to London at theeastern end of the runway by a short spur road, which would also serve the regional A&E centreat the Royal Surrey Hospital.

(f) The loss of just two residential properties. The majority of the land required for the developmentis currently under the control of the Directors of the company.

(g) A reduction of noise over Redhill and Nutfield caused by the termination of the current generalaviation training circuits—a noise survey in 1994 showed that some 1,500 households were aVectedby noise at 57 Leq.

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(h) The new alignment and approach paths are expected to result in an extra 20 residences beingexposed at 57 Leq, but with at least 500 being taken out of the existing noise nuisance category—a net benefit to local residents. Almost all of the 57 Leq contour is over open Green Belt land.

(i) The proposal would be of benefit to BAA as the owners of Gatwick Airport. With large numbersof smaller regional aircraft transferring to Redhill, the slots made available could be used byadditional long-haul aircraft with greater passenger loads, enabling Gatwick Airport to make bestuse of its existing facilities at the same time as the facilities at Redhill are also used to best eVect.This proposal meets ALL of the requirements as outlined in paragraph 264 of the SelectCommittee’s conclusions to its 2003 report on Aviation, in particular in relation to making bestuse of existing facilities—a conclusion re-iterated in the executive summary of the subsequentWhite Paper.

(j) This development could proceed without impacting on BAA’s agreement with West Sussex CC notto construct a second runway at Gatwick before 2019.

(k) Given the speed and low cost of this proposal Redhill hopes that it will be the chosen option.

3. Response to Question 1

Question 1. (a) What changes to the management of airspace could be required as a result of the additionalairport capacity outlined in the 2003 White Paper? (b) Are the White Paper’s projections for increasedpassenger demand still accurate? (c) Are all the measures to provide for increased passenger demand likely tobe implemented?

3.1 It should be noted that although the total passenger numbers for 2007—at some 241 million—are inline with the original DfT 2000 forecasts going into the White Paper, the geographical distribution in termsof average aircraft size and airspace routes taken has changed substantially particularly as a result of therapid growth of low cost airlines. Substantial change had already occurred at the time the White Paper wasproduced in 2003 due to the growth in the low cost carriers and the impacts of 9/11. RAL is concerned thesedistribution changes were not accounted for in the White Paper, impacting the DfT conclusions drawn onwhere additional airport capacity is most needed, as well as the airspace management issues for NATS. RALwould urge the Government to revisit the Transport White Paper in the light of the Airport Master Plansproduced in response to it. In particular the DfT should verify that the forecast distribution of passengerdemand to 2030 will be adequately matched by realistic projections of capacity and airline requirements forrunway development, particularly in relation to Gatwick, thus Redhill.

3.2 It is recognised that BAA is requesting additional runways at Stansted and Heathrow in line with theexpectations of the White Paper, and that the fall-back position of a second runway at Gatwick remains ifthe Heathrow application fails. However, there is no guarantee that planning permission (either locally orvia the newly established Infrastructure Planning Commission) will be given for any of these runways.

3.3. There is thus no guarantee that the measures to provide for increased passenger demand in South EastEngland will be implemented, or that any new runways will be in the most suitable location. RAL stronglydisagrees with the BAA view that all runways in the South East are fully substitutable for each other.

4. Response to Question 3

Question 3. (a) Is the current approach to planning and regulating the use of UK airspace adequate? (b)Would an Airspace Master Plan covering the period of the White Paper be beneficial? (c) Could a piecemealapproach to individual developments necessitate additional redesigns subsequently?

Part (a)

4.1 RAL is not convinced that the current approach is adequate. Planning by NATS seems to becompletely re-active and not pro-active. When requests have been made to NATS to consider how asubstantial increase in movements can be accommodated at Redhill, the response is always a knee-jerkreaction that nothing is possible. At the first such request in 1993, the response was that no more than sixmovements an hour could be accommodated without jeopardising the movement rate at Gatwick Airport.15 years later, the answer is similar.

4.2 This is identical to the initial response given to the original owners of London City Airport, whichcould not be accommodated due to the impact it would have on Heathrow. NATS have since “learnt” thatthe airspace around London City can comfortably handle today’s 91,000 annual movements, nowapparently constrained only by the physical characteristics of the airport’s runway and taxiway—notairspace considerations.

4.3 A similar negative response was given to the initial request for a direct helicopter service betweenGatwick and Heathrow—‘it would have to be routed via Biggin Hill and join the long fixed-wing approachto Heathrow’. They had to be proved wrong over time. Similarly, the SERAS proposal for an airport at CliVewas damned by NATS before any detailed airspace planning had been undertaken.

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4.4 It was only the dogged persistence of the owners of London City and the operators of Airlink thatovercame the innate conservatism of NATS. We at RAL are faced with the same intransigent views, and areopposing it with the same thoroughness, putting forward the more positive views of other airspace expertssuch as SERCO, (who wrote a positive report in 2003), and of airspace consultants.

4.5 As for regulation, it would appear that the CAA asks NATS for its views and appears to accept themwithout taking second opinions, or checking with best practice in Europe and elsewhere. RAL does notbelieve that this is good either for the airspace sector, or for UK aviation as a whole.

Part (b)

4.6 The White Paper specifically asked for Master Plans to be drawn up for all major airports, but didnot simultaneously request an airspace Master Plan. Ideally, the UK would benefit from such a plan thatwas based on a firm knowledge of current and projected runway developments, that was robust and thatcould accommodate “unknown” developments, both in runway provision and of changes in aircraft typesand mix. Runway capacity and airspace capacity are crucially linked. They must be planned together.

4.7 However, it is accepted that until airport development decisions have been made, a Master Plan wouldbe almost impossible to produce for the South East of England. The impact of a second runway at Stanstedand/or a third runway at Heathrow would be so substantial that a whole new airspace pattern over asignificant part of the UK would be necessary. Once these runway decisions have been taken, it may bepossible to draw up a Master Plan that not only accommodates these developments, but also allows for thepossible introduction of additional runways at airports such as Luton and Redhill, as proposed at the timeof the White Paper, although not favoured at that time.

4.8 RAL’s concern is that any Airspace Master Plan would eVectively “freeze” the development ofrunways as at the time of study, and that any future developments would become impossible. For example,the tentative airspace plans for accommodating a third runway at Heathrow push more traYc to the southof Heathrow than currently happens, which will circumscribe operations at Redhill even more tightly; butif Redhill had been approved, the Master Plan would have had to be drawn up with that knowledge, andchanges made to accommodate all growth equally.

Part (c)

4.9 Regrettably, RAL believes that the current approach is probably more sensible: that ideas for airspacedesign can be mulled over while plans for new runways are discussed, but that detailed design is onlyworthwhile once a decision to build a new runway has been taken. Then, NATS can work with “facts” andconstruct a revised airspace plan to cope with predicted traYc flows.

4.10 In the consultation for Heathrow’s Third Runway, it is clearly stated that NATS has not yet madefirm decisions on how the airspace will be re-designed, but that certain generalities could be drawn. Forexample, Northolt would have to be closed, runway approaches to Farnborough would be aVected, andcertain flows from Heathrow’s existing runways would be diverted from the north side to the south side ofthe airport. Once any decision to go-ahead is taken, NATS will be able to firm up these ideas into detailedplans, based on the known runway provision in South East England at that time.

4.11 It is important to note however, that NATS have committed to making Heathrow Three work, eventhough the detailed studies have yet to be undertaken, unlike its earlier pronouncements on London City,CliVe and Redhill. If approval is eventually given for the expansion of Redhill’s runway and air transportmovements, NATS will have to commence its studies from the then status quo, possibly including a secondStansted runway and a third Heathrow runway, but it would not need to take into consideration a possiblesecond Gatwick runway.

5. Response to Question 6

Question 6. What opportunities are there to apply new techniques and technologies to reduce wasteful flyingon indirect routes and excessive “stacking” while planes wait to land? How can the potential of any suchopportunities best be realised? Could environmental benefits be gained as a result of such improvements?

5.1 Consultants retained by RAL have been active participants in the current SESAR studies and areaware of the numerous technical developments being studied to improve airspace use throughout Europe,leading eventually to the gate-to-gate concept. These would minimise the use of stacks, lead to reduced fuelusage and oVer noise benefits to residents close to airports.

5.2 Although NATS were also participants, it is not clear whether their current airspace plans take fullyinto account the possibilities of radical change in airspace management, including the provision of theirFACTS (Future Area Control Tool Support) system. These developments will increase capacity of currentairspace and would almost certainly allow developments (such as a fully-used runway at Redhill) whichpreviously were rejected, based on existing airspace management processes and ATM systems.

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6. Response to Question 7

Question 7. In relation to the redesign of UK airspace, is the allocation of the roles and responsibilities of eachof the interested parties—Department for Transport, the CAA, airport operators, NATS, etc—appropriate andclearly understood? Are the structures of the parties appropriate for undertaking the roles that they should play?

6.1 RAL are concerned about the close relationship between NATS and one of its major shareholders,BAA. BAA holds 4% of the shareholding in NATS following an approach by the Government in 2003 toinvest a further £65 million to staunch a reduction of NATS funds shortly after privatisation.

6.2 RAL believes that if BAA had wanted Redhill to be developed so as to improve its own financialreturn at Gatwick, then NATS would have been more positive about the possibility of Redhill being able tohandle the necessary movements. The contrast of the “can do” for Stansted and Heathrow is in sharpcontrast to the “can’t do” for London City, CliVe and Redhill.

6.3 RAL is also concerned about the very close relationship between the DfT, the CAA and NATS, andthe apparent lack of any depth of management knowledge to challenge NATS opinions. The possible adventof EASA as an interested partner is viewed positively by RAL.

7. Response to Question 8

Question 8. (a) Do airspace management considerations delay the planning processes in relation to airportdevelopment proposals? (b) How will airspace management considerations be taken into account by theproposed new Infrastructure Planning Commission and the relevant National Policy Statements on airportplanning?

7.1 As can be seen from earlier answers, all that NATS is currently able to oVer at the planning stage forrunway developments is a set of concepts and ideas about how airspace could be designed following the go-ahead for a new runway. It will be able to give indications of areas likely to be aVected by overflying, butthese will not be firmed up until after a decision has been made. In that sense, yes, airspace considerationsunnecessarily delay planning the process.

7.2 In the case of Redhill, a negative assessment (based on initial thoughts and not on detailed studies)was used by the DfT in its White Paper as the sole reason to refuse to consider the undoubted benefits thatcan still be oVered by a feeder-reliever runway at Redhill. If this view had not been given, the DfT wouldhave no other reason to go along with BAA’s view that it did not want additional further competition fromRedhill (White Paper, paragraphs 11.117—11.119).

7.3 Airport managements with the inside track to senior DfT oYcials appear to work (successfully)against valid proposals from other airports.

7.4 Redhill, although not considered five years ago, is as strong a runner, if not stronger today.

RAL would welcome the opportunity to give additional verbal evidence to the Select Committee ifrequested.

September 2008

Memorandum from Gatwick Area Conservation Campaign (AIR 05)

Summary

— The White Paper forecasts are inaccurate due to the price of oil, the lack of tax, and theunderestimate of climate change costs.

— Flights over rural areas, and the concentration of flight paths on narrow tracks, causedisproportionate disturbance and annoyance. It should therefore not be assumed that rural areasprovide unlimited space for new flight paths.

Introduction

1. GACC is the main environmental group concerned with Gatwick Airport. Founded in 1965, we haveover forty years experience of trying to find rational solutions to the problems caused an major airport. Ourmembers include over 100 councils and environmental groups covering an area about twenty miles radiusaround Gatwick.

2. We wish to comment on two items mentioned by the Select Committee as matters in which they areinterested.

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Forecasts

Are the White Paper’s projections for increased passenger demand still accurate? Are all the measures toprovide for increased passenger demand likely to be implemented?

3. We believe that the White Paper projections, and indeed also the Forecasts of UK Passenger Demandproduced by the Department for Transport in December 2007, are seriously inaccurate for the followingreasons.

4. The White Paper was based on a forecast cost of oil (or aviation fuel) of $25 per barrel. The DfTforecasts depend on the unlikely assumption that the price of oil falls to $53 per barrel. Although the costof oil has fallen from its peak earlier this year, few experts would now predict that it would fall to $53, letalone £25.

5. The forecasts are also based on the unlikely assumption that during the next 25 years there is noincrease in tax on air travel in order to raise revenue.

6. Also that any tax imposed for climate change reasons (or the cost of emissions trading permits) willbe at an exceptionally low rate—based on the DEFRA social cost of carbon which in turn is based on theunlikely assumption that all other countries take drastic action to reduce their CO2 emissions, with no needfor the UK to take a lead.

7. These points are spelt out in the booklet Fallible Forecasts written by the Aviation Economics Group.

Rural Areas

How are the eVects and aircraft noise and emissions taken into account when changes are made to the use ofairspace? Who should be consulted about such changes? How should the balance between conflicting interestsbe struck?

8. We have considerable experience on these issues, having been involved in matters relating to Gatwickflight paths for over 40 years. We welcome the fact that consultation is now required for new flight paths:many flight paths at Gatwick were established before consultation was required.

9. The consultation recently carried out by NATS for Terminal Control Area North, although it did notdirectly aVect the Gatwick area, appeared adequate in its coverage.

10. Most flight paths to and from Gatwick are over rural areas. Gatwick is surrounded on three sides byAreas of Outstanding Natural Beauty, and most aircraft approaching or departing fly over these areas. Weconsider that it would be incorrect to assume that there is a simple numerical relationship between thenumber of people aVected when flights are re-directed from over towns to over rural areas. Aircraft noisein rural areas tends to be more annoying for two reasons. First there is a lower background noise. Secondthere is a greater expectation of peace and quiet.

11. The expectation of peace and quiet in the countryside is the reason why many people chose to livethere. This is documented in literature and in tens of thousands of house advertisements. Therefore there isgreater annoyance when this peace is destroyed by aircraft noise. The annoyance becomes even greater whenit is a result of a deliberate change in the use of air space. There is resentment because the previoustranquillity has been deliberately destroyed, and also because house values fall in the aVected areas, lockingpeople into their properties so that they cannot move away without financial loss.

Narrower Flight Paths and New Routes

12. The concentration of aircraft on narrow routes is causing an increasing problem. The policyestablished in the early 1970’s was that there is an environmental benefit in confining aircraft to specificroutes. In recent years, however, the improvements in aircraft navigation have narrowed the swathes andthis will become even more apparent with the introduction of P-RNAV. This means that all the noise andannoyance is concentrated on comparatively few people. While many benefit, the unlucky few suVer misery.A great feeling of injustice is created. One of the basic human rights—to the peaceful enjoyment of one’shome—is infringed.

13. Where people buy a house, knowing that it is under a flight path, they normally pay a lower price,and accept the situation. But when a change in routes is imposed on innocent and unsuspecting people theyfind their house devalued, and cannot move without suVering loss. They therefore feel trapped by theaircraft, and the sense of resentment is magnified.

14. These points are confirmed by the high level of opposition to the new flight paths recently proposedby NATS for Terminal Control Area North. Over 15,000 responses were submitted with over 80% againstthe new proposals, with the main concern about the impact on rural areas and on tranquillity.

15. The balance between conflicting interests cannot be struck by counting heads: the magnitude of thebenefit or dis-benefit needs to be assessed.

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16. Although, as explained above, we do not consider the doubling or trebling of air travel as envisagedin the Air Transport White Paper is likely to occur, if it did it would mean a vast increase in the number offlight paths over the UK, or a vast increase in the number of aircraft using existing flight paths. This wouldmean that the public opposition to aviation expansion would be on a far wider scale.

September 2008

Memorandum from the Manchester Airports Group plc (AIR 06)

1. Introduction and Executive Summary

1.1 This is the submission of the Manchester Airports Group plc (MAG) to the Call for Written Evidenceissued by the House of Commons Transport Committee in connection with its inquiry into the use ofairspace.

1.2 MAG is the UK’s second largest airport operator and comprises the airports of Manchester, EastMidlands, Humberside and Bournemouth. MAG handled over 29 million passengers in 2007–08, withManchester alone accounting for over 22 million passengers travelling to over 220 destinations, more thanany other UK airport.

1.3 MAG is publicly owned by the 10 local authorities of Greater Manchester. These shareholders requireus to grow the business profitably, to enhance the value of the business; and to maximise the economic andsocial contribution to the regions it serves.

1.4 The main points of this submission are as follows:

— The developments outlined in the 2003 White Paper require a substantial increase in airspacecapacity for civil aviation.

— There should be a national Airspace Master Plan.

— The CAA’s Directorate of Airspace Policy should drive the production of such a plan, with others(NERL, airports, other industry stakeholders) providing a supportive role.

— More military airspace should be released for civilian purposes.

— Increases in airspace capacity or reorganisation, will deliver substantial climate change benefits,and are a “win-win” solution.

— “Mid level airspace” flying should be discounted when considering environmental (specificallynoise nuisance) factors.

— The EU’s Single European Sky II package should be supported in principle.

— New technology and procedures, and quicker planning approvals for airport projects will have arole in reducing delays. The process for airspace change and masterplanning needs to run at thesame pace.

— Commercial aviation’s requirements should take precedence over recreational and other flying,and should follow the SES policy proposals for prioritising airspace use.

— The world-wide shortage of controllers will cause diYculties, though to an extent these may bealleviated by technology and the release of airspace.

— Government should fund the production of the national airspace Master Plan.

1.5 The management of airspace, both in respect of en-route functions and for local air traYc controlpurposes, is heavily dependant on the use of radio spectrum frequencies for both voice communication,navigation and to ensure flight safety. MAG views with concern the proposed introduction by Ofcom of acharging mechanism (“Administered Incentive Pricing”) for the use of radio spectrum for aeronauticalpurposes from 2009 and will be registering its strong objections to Ofcom in our response to its recentconsultation paper. We are particularly concerned with the way that Ofcom has handled the consultationprocess over this proposal which has resulted in airports apparently being omitted from the consultationprocess until very late in the day.

This proposal, when implemented, will result in significant cost increases for airports (circa £1.2 millionfor Manchester Airport alone) being imposed at relatively short notice.

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2. Responses to Questions

2.1 What changes to the management of airspace could be required as a result of the additional airport capacityoutlined in the 2003 White Paper? Are the White Paper’s projections for increased passenger demand stillaccurate. Are all measures to provide for increased passenger demand likely to be implemented?

The 2003 White Paper projected increases in air travel of between two and three-fold in the years up to2030. Subject to shorter term fluctuations to reflect economic cycles, MAG believes that these forecasts arestill valid and will be reflected in the further development of the UK airports industry in order to meetthat demand.

The White Paper recognised the need for a structured programme for the redesign of UK airspace thatwould help protect safety standards, relieve current constraints, take account of environmental impacts andaccommodate the forecast increase in air transport movements where additional capacity was supported inthe White Paper. It is essential that the UK has such a structured airspace programme.

The White Paper (paragraphs 12.26–12.27) places the responsibility for planning the necessary structuredre-design of UK airspace and the introduction of enhanced technologies and systems, firmly in the handsof the Civil Aviation Authority (CAA). In doing this, the White Paper acknowledges that the CAA will needto involve other parties, including both NATS en-route (NERL) and airport operators in working up itsproposals.

MAG does not believe that this responsibility has yet been fulfilled by the CAA. The CAA’s currentDirectorate of Airspace Policy, where arguably the responsibility for such strategic planning lies, is currentlyconstituted as a policy and regulatory body, relying on others, principally NERL and in limited cases,airports to put forward proposals.

Although the CAA, NERL and the Department for Transport have set in place the Future Airspace Studyto establish the parameters for strategic airspace planning until 2030, this initiative is still ‘work in progress’,the results of it are yet to be seen and MAG is not aware of the timescale for its completion. If the FutureAirspace Study results in an eVective Master Plan for UK airspace, then this fact needs to be more widelypublicised. MAG is unaware of any consultation initiatives either by the CAA or NERL about any“national master plan” for UK airspace.

In the apparent vacuum created by the absence of a national master plan for airspace, such planning asis undertaken is done by NERL, and is necessarily done on a piecemeal basis, in response to shortagesidentified locally. Notably, NERL has a limited resource for this type of development and is not in a positionto be able to accelerate such work. MAG does not believe that this approach will enable the necessaryincreases in airspace capacity to be achieved in the longer term.

Airspace is one of the four key capacity drivers that govern the ability of the industry to meet the needsof its users. The others being runways; terminals and surface access. Plans and strategies to deliver thenecessary uplift in capacity of these elements have already been prepared by airport operators through theirMasterplans. Those plans could be frustrated by the failure to adopt a similar approach to airspace.

Manchester Airport suVers to an extent from an outdated airspace structure designed to handle forecasttraYc levels predicted in the 1980s.10 At peak times, airspace can be a constraint on airport capacity. Thereare conflicts between departure and arrival routes that require complex coordination between Manchesterand Liverpool traYc as well as between aircraft flying through the area in the same controlled airspace.NERL’s current programme of capacity enhancement includes a restructuring of the Terminal MovementArea (TMA) for the North West, and should have a relieving eVect in the medium term. However, asindicated above, this is an Upper Airspace based piecemeal approach, and MAG would prefer the need forsuch an approach to be lessened by the production and maintenance of a national airspace masterplan.

2.2 Can safety be maintained as airspace is increasingly utilised? Is there a suitable interface between militaryand civilian arrangements for air traYc control?

Safety in the skies can never be compromised, but MAG is of the view that within the currentarrangements it will not be possible to substantially increase overall airspace capacity, without increasingthe number and length of delays inherent in the “system”.

Operationally, there is a good interface between civilian and military airspace utilisation, but at thestrategic level, this interface is less beneficial. There is a strong perception of military precedence whenconflicting demands for airspace occur, which appears to leave the civilian sector disadvantaged. This maybe a result from legacy/historical factors.

The release of military airspace to civilian use would enable more direct routings of flights and increasethe amount of capacity available to commercial operators. Such changes would have both operational andenvironmental benefits. They are a “win-win” solution, which require no apparent sacrifices from airtravel users.

10 See the Department for Transport Improving the Air Passenger Experience—an analysis of end to end journeys with a focuson Manchester Airport, published September 2008, pages 36 and 43.

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Short term releases of military airspace for civilian use, for example that happens in certain areas atweekends, whilst operationally useful, oVer no long term certainty or increase in the overall planned capacityof the system.

2.3 Is the current approach to planning and regulating the use of airspace adequate? Would an Airspace MasterPlan covering the period of the White Paper be beneficial? Could a piecemeal approach to individualdevelopments necessitate additional re-designs subsequently?

MAG does not believe that the current approach to planning UK airspace is adequate. It is piecemealand incremental, lacks a clear strategic direction and is bureaucratically cumbersome. It suVers from similardeficiencies as the current UK Planning system, and like that system has become increasingly complex andrisk averse recently, with an increasing propensity for matters to be referred to Judicial Review.

The type of Master Plan that MAG advocates should take as its starting point the presumption that thedevelopments outlined in the 2003 White Paper, will be delivered. This national policy would then providea strategic framework and set a presumption in favour of airspace changes that accorded with the plan (againparalleling the town and country planning system).

2.4 How are the eVects of aircraft noise and emissions taken into account when changes are made to the useof airspace? Who should be consulted about such changes? How should the balance between conflicting interestsbe struck?

The overriding principle that applies (as it does at the present) is that no environmental degradationshould take place as a result of such proposals, and in the worst case scenario a position of neutrality shouldbe regarded as the minimum.

Those aVected by such proposals should be adequately consulted, but an important factor to beconsidered is the height at which aircraft are considered to be capable of causing a noise nuisance.Traditionally this was regarded as aircraft flying in “lower level airspace” (ie up to 7,000 feet), but MAGnotes with alarm the view in some quarters that aircraft flying in “mid level airspace” (seven to 17,000 feet)should also be considered a source of nuisance (and in spite of modern aircraft being much quieter than thoseof 10-20 years ago). MAG would oppose any such move. Many short haul routes, eg Manchester—Heathrow, would be caught in their entirety by such a change, either because such flights are kept artificiallylow because the space higher up is too congested, or because they are operated by turboprop aircraft orregional jets that do not fly above such levels. Taken to its logical conclusion, such a development couldnecessitate consulting the entire population aVected between the two airports.

Striking the balance between conflicting interests is covered by Government policy and MAG takes theview that the existing arrangements should prevail.

It greatly complicates and slows down the process if each airspace change has to argue from “firstprinciples” in respect of the need for change or benefits thereof. An overall UK airspace Masterplan istherefore required.

2.5 How does the management of airspace in the rest of Europe aVect flights into the UK? Is there anopportunity to integrate our plans for changes to airspace management more eVectively with those of otherEuropean countries?

There is some international cooperation that has benefits in this area, in particular between the UK andthe Netherlands and the UK and the Republic of Ireland. MAG supports the view that airspace should bemanaged on a wider basis than following national boundaries and supports, at a high level, the moves beingtaken by the EU to achieve further progress in this area through the recent Single European Sky II package.

It needs to be recognised that heavy demands are made on UK airspace by the large volumes of overflyingtraYc destined for many parts of Europe from over the North Atlantic. This imposes constraints on UKusers and increases the demands on the capability of the UK’s systems. This eVectively can and will lead toairspace being denied to UK-originating traYc and to delays being imposed on such traYc.

2.6 What opportunities are there to apply new techniques and technologies to reduce wasteful flying on indirectroutes and excessive “stacking” while planes wait to land? How can the potential of any such opportunities berealised? Could environmental benefits be gained as a result of such improvements?

Wasteful flying can be reduced by release of additional airspace from current military use, by new AirTraYc Control technologies and procedures, eg, Continuous Descent Approaches (CDA), by reorganisingand planning airspace on a national or supra-national basis, and by speeding up the planning approvalprocess for major airport projects so that airport capacity is not unduly restricted. MAG believes that thereare significant environmental benefits to be gained from implementing all these proposals. The mostsignificant benefits will be from more direct routing (estimated to reduce CO2 emissions by up to 10%) and

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by improved flight profile and approach procedures (between 3.1 and 6.6% per cent benefit),11 which areproven procedures requiring no new technology or investment. But the expansion of their use is nowconstrained by having to operate within historic airspace boundaries and designs. Improved flight profileand approach procedures such as CDA also means less noise, less disturbance to residents and lower fuelburn.

2.7 In relation to the re-design of UK airspace, is the allocation of roles of each of the interested parties—Department for Transport, the CAA, airport operators, NATS, etc, appropriate and clearly understood? Arethe structure of the parties appropriate for undertaking the roles that they should play?

MAG does not think that the roles of the parties are clearly understood insofar as none of the parties hastaken a strategic ‘lead’ responsibility for airspace planning and design, eVectively driving the whole processforward. MAG believes this to be primarily a CAA responsibility, and such a role is clearly implied by the2003 White Paper, with NERL and DfT acting in a supportive capacity. MAG is of the opinion that thisfunction should not be regarded as matter of equal joint responsibility; such a process would cause confusionand delay. There is no fundamental reason why such masterplanning and airspace regulation cannot becarried out by the same body, provided the appropriate safeguards are maintained to prevent conflicts ofinterest.

As an airport operator, MAG does not believe that the current process for overall airspace capacityplanning works well, for the reasons outlined in para 2.3 above. MAG has to react to the deficiencies of thecurrent piecemeal airspace planning process, which is unsatisfactory, slow and lacks clarity. Currently onlyNERL has all the data on flight delays, and determines priorities for airspace change, yet the current systemis less than clear about how some of these arise.

2.8 Do airspace management considerations delay the planning processes in relation to airport developmentproposals? How will airspace management considerations be taken into account by the proposed newInfrastructure planning Commission and the relevant National Policy Statements on airport planning?

Airspace management considerations do not normally aVect planning processes for airport developmentproposals, although a recent exception was the case involving Coventry Airport.

Deficiencies in airspace capacity will, in the longer term, have an eVect on whether airports are able tobring forward development proposals. If airspace is the weakest link in the capacity chain then this negatesinvestment and improvements in the capacity of the other key elements. Delays in bringing forward suchproposals will adversely aVect the contribution that airports can make towards stimulating regionaldevelopment.

MAG is not aware of how National Policy Statements will take into account airspace capacity issues, andwould prefer to see a National Policy Statement on airspace that successfully addresses the matter, or itsinclusion in the Aviation National Policy Statement.

2.9 What could be the implications for smaller airfields, recreational flying and helicopters of changes toairspace management to enable safe & eYcient increases in capacity at the UK’s major airports/How shouldan appropriate balance between conflicting priorities be determined?

There are very few implications for these types of aviation activity because most rely on flying at very lowaltitudes where Visual Flight Rules (VFR) procedures are the norm, and where interference with and use ofcontrolled airspace is unlikely.

Where there is a conflict, commercial aviation should take precedence. Recent history shows that theinterests of the users of this type of aviation activity are arguably more than adequately catered for undercurrent arrangements. Indeed MAG believes that other users are accommodated sometimes at the expenseof commercial aviation. We note that these users are represented proportionately more than commercialaviation and airport interests at the forums sponsored by the CAA’s DAP.

2.10 Will it be possible to recruit and train staV in order that airspace changes can be implemented in parallelwith additional airport capacity?

There is a world-wide shortage of air traYc controllers and this will impact on the future development ofadditional airspace capacity, unless technological changes, structural changes and release of defence-controlled airspace can enable better utilisation of existing staYng resources. Whether such changes fullycompensate for growth in demand for airspace, and result in a reduced demand for controllers, is doubtful.

Arguably, better airspace design is more eYcient and needs less controllers. Automation in aircraft couldlead to less reliance on traditional ATC methods.

11 See EU communication COM(2008) 389 final.

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Failure to address airspace capacity shortage will, paradoxically, cause an increase in the short termdemands for both air traYc controllers—in order to control complex and congested airspace, and will alsolead to a requirement to build additional apron and taxiway capacity at airports—to enable aircraft to beheld on the ground for longer periods whilst waiting for slots to become available for the en-route sector ofany air route.

2.11 Who should fund airspace changes? Is there likely to be enough funding to undertake the redesign requiredto bring about the necessary additional airspace capacity?

MAG considers that the responsibility for funding airspace planning falls squarely on the shoulder ofGovernment. It is up to Government to ensure that the necessary structural planning of UK airspace isgranted suYcient funding so that the overall long term interests of UK plc are not disadvantaged. MAGdoes not consider that the funding of such planning should fall on current users either via airports or viaNERL. Such a source of funding would encourage a continuation of the current short term localisedapproach.

The airports are responsible for delivering the other 3 main aspects of capacity; airspace is a truly nationalresource.

October 2008

Memorandum from Shropshire County Council (AIR 07)

Summary

— Shropshire County Council (SCC) has an interest in the impact of increasing Civil Air TraYc overShropshire with regard to its eVect on tranquillity in a rural county and consequences for carbonemissions and climate change targets.

— The Civil Aviation Authority (CAA) implemented West End Area Airspace changes in March2006, the result in Shropshire being a 21% overall increase in air traYc over-flight of the ShropshireHills Area of Outstanding Natural Beauty(AONB).

— Some residents perceive a significant loss of tranquillity in a rural county and have madecomplaints accordingly.

— Shropshire County Council ask Government to commission research and detailed studies onmeasuring tranquillity and mitigating impacts of aircraft noise on tranquillity, and also to seek theproduction and evaluation of noise criteria with regard to air traYc.

Background

1. Civil Air TraYc over the County of Shropshire has been considered by Shropshire County Council,with regard to increasing frequency and noise intrusion, most recently at its Cabinet meeting on 24September 2008, and prior to that at the Economy and Environment Scrutiny Panel meeting on 11September 2008.

2. The background to our interest in this topic came about in March 2006, when the (CAA) and NationalAir TraYc Services (NATS) implemented the West End Airspace changes. The principle aims of the changeswere to improve air safety and eYciency in the face of increasing demand for commercial air travel, and alsoaddress the needs of the Ministry of Defence (MoD). In June 2008 the CAA issued the West End AirspaceChange Review report on the impacts of the changes.

3. This response to the Transport Select Committee Inquiry into the use of airspace relates primarily tothe issue of how the eVects and aircraft noise and emissions are taken into account when changes are madeto the use of airspace and how the balance between conflicting interests should be struck.

Impacts of Recent Airspace Changes over Shropshire

4. The CAA report (West End Airspace Change Review; 30 June 2008) confirms that the redesign andrevised arrangements to the airspace, both above and below flight level FL245 (24,500ft) were based on aneed to reduce delays to commercial aircraft and deliver a substantial increase in Air TraYc Services (ATS)route capacity of 30%. From the MOD perspective suitable airspace sharing arrangements were establishedto ensure existing and future operational capability.

5. The report details areas of contention to the changes, relating to the environment, and makes referenceto the concerns of SCC and the Shropshire Hills AONB. It concluded that it considered it impracticable toavoid over-flight of aVected AONB’s in the proposal due to the complexity of achieving this in practice.

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6. The volume of air traYc over-flying the county is increasing year on year. On analysis, the impact ofthe change on the Shropshire Hills AONB is that a slightly larger area is over-flown than before and the baseof controlled airspace overlying the eastern side is lower. The overall increase in flights is 21% (an additional47 flights per day). The County Council is seeking an explanation from the CAA as to why the increase wasso much greater in Shropshire than for other sensitive areas, and the UK as a whole.

7. Some residents who live below the flight paths find the level of increase to be very intrusive in adesignated area. The increase in civil aviation, together with the busy routine activity of the MOD hasgenerated some strong comment from individuals concerned. We also have received numerous complaints.However it is apparent that individuals’ perceptions of the extent of the problem vary. The Council aYrmsits support for the work of the armed forces in Shropshire and would not wish to impinge on militaryactivities but, nevertheless, hopes that the forces will be sensitive wherever possible to the impact ofoperations on the community.

8. Shropshire welcomes the fact that, when compared to other similar sectors, analysis of safety records,show that the West End sectors have seen a reduction in the number of incident reports, as a result of thechanges to airspace introduced in March 2006.

Environmental Considerations

9. We understand that there is a paucity of available research and models for the appropriateconsideration of the issues around tranquillity and noise intrusion from aircraft, as it aVects communitieson the ground.

10. We understand that the CAA had commenced dialogue with Campaign for the Protection of RuralEngland (CPRE) to gain an understanding of better measurement of tranquillity with regard to air traYcnoise. This was promised back in 2006, but to date no progress has been reported. There remains a need forgovernment to commission detailed studies on measuring tranquillity, methods of mitigating the impacts ofaircraft noise and also the production and evaluation of noise criteria with regard to air traYc.

11. While it is clear and appropriate that a wide range of environmental bodies are routinely consultedabout airspace change proposals, together with public and private bodies beneath the flight paths, it remainsextremely diYcult to achieve consideration of, or mitigations for, loss of tranquillity. Economic and aviationfactors are considered of greater significance. Better informed guidance and objective measurement ofimpacts on tranquillity is needed to help strike the balance between conflicting interests. The County Councilis further concerned about the wider implications of increasing Air TraYc on national climate changetargets.

Conclusions

Shropshire County Council welcomes the Transport Select Committee inquiry into the use of airspace.

The County Council believes that the lack of research into the issue of air traYc noise and tranquillity isan obstacle to meaningful consultation and evaluation of impacts, and request that government take stepsto commission appropriate studies and develop methodologies in this area.

The County Council understands the strong views about how changes to airspace over Shropshire aVectsour residents, together with the complexity of striking a balance between MOD needs, local communities,the increasing demand for air travel and the economy and the environment.

October 2008

Memorandum from the Ministry of Defence (AIR 08)

Overview

1. The Transport Select Committee’s Inquiry into the use of Airspace concentrates on exploring ways ofmeeting the rising demands of commercial aviation, however, it is essential that that any future demands ofcommercial aviation are balanced against the overriding need to maintain and develop the UK’s MilitaryCapability, in particular National Security.

The singular most important element underpinning the MoD’s strategic aspirations and requirementsdetailed below is access to airspace that will enable all arms of the MoD to “train as they would fight” inorder to counter immediate threats to the UK and to be fully prepared to meet any future challenges.

Accordingly, the MoD’s responses to the specific questions posed by the Inquiry should, at all times, beframed by the strategic context outlined below.

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Future Air and Space Operational Concept

2. The UK’s air and space power capability out to 2020 is described in the Future Air and SpaceOperational Concept (FASOC). An Agile Air Force is the core of the capability encompassing Air Powerelements from all 3 Services integrated to deliver future air and space power. Agile air power is fundamentalto the UK’s future Military Capability.

3. The FASOC describes the development of the UK’s air and space contribution to Joint and Coalitionoperations. High-level policy direction derives from the Strategic Defence Review and the New Chapter,Defence Strategic Guidance 2003 and the Defence White Papers 03 and 04. It is further guided by the UKJoint Vision, the Joint High Level Operational Concept and the UK Military EVects-Based OperationsConcept, and informed by other emerging concepts. It is consistent with, and links to, the Future MaritimeOperational Concept the Future Land Operational Concept and developing Future Logistics OperationalConcept.

4. Defence planning acknowledges the increased likelihood of deploying forces beyond the core regionsto deliver a small-scale military response across the globe to counter asymmetric threats. Moreover, as amore closely defined force for good, our humanitarian eVorts are likely to be in demand world-wide.

The Defence Aim

5. The UK’s air and space capability contributes to the Defence Aim:

To deliver security for the people of the United Kingdom and Overseas Territories by defending them,including against terrorism, and to act as a force for good by strengthening international peace and security.

6. The UK achieves the Defence Aim by being able to meet 18 Military Tasks which are grouped underthe headings of Standing Strategic Tasks, Standing Home Commitments, Standing Overseas Commitmentsand Contingency Operations Overseas. Air power underpins the delivery of Joint capability across themajority of Military Tasks. Air Power’s unique attribute is that it oVers operational choice without,necessarily, any commitment to action or to deploy troops on the ground.

Agile Air Power

7. To meet the demands of the strategic environment, the UK’s air power capability must be strategically,operationally and tactically agile. To deliver agility aVordably, the structures, processes and equipment mustbe utilised across the widest range of roles and suYcient personnel must be trained to support and exploitthe breadth of air power’s capability.

8. Defence Planning Assumptions identify the type and scale of operations that must be met concurrentlyin addition to the Standing Home Commitments and Standing Strategic Tasks which must continue to bemet. Current guidance is that an adaptive force structure must be developed that can routinely and rapidlymeet the most likely and frequent scenarios while retaining the ability to generate appropriate forces for themost demanding and deliberate, but less likely and less frequent, operations. In the FASOC timeframe,structures, processes and equipment must also be designed to be suYciently flexible so as to be able torespond as threats, technology and alliances evolve. The greatest risk to UK security is that the strategicenvironment will change faster than the UK can or will acquire and apply resources to meet that threat. Aninability to access airspace where and when it is needed would significantly undermine military preparedness.

National Security

9. Air Power’s principal Standing Home Commitments Military Task is the protection of UK sovereigntyand security at home. The UK Airspace Security task objective is:

To provide a continuous recognised air picture and an air policing capability, providing for theinterception and possible destruction of rogue and hostile aircraft, to maintain the integrity of the UK’sairspace.

10. The task is co-ordinated by the Home OYce and involves critical military support to, and close co-ordination between, Other Government Departments (OGDs) and both military and civilian airspacecontrol agencies, including those of neighbouring nations. The speed with which a threat to the UK’sairspace security can emerge drives the need to develop highly responsive, well co-ordinated Command andControl structures, processes and people capable of an integrated, time-critical and appropriate response.A responsive, flexible, potentially lethal counter-air capability cued by persistent surveillance of the air, andrealised through a networked capability across the military/civilian interface, is vital to ensure protection,especially from an asymmetric threat, and, importantly, to provide eVective deterrence.

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Military Airspace Utilisation

11. Any future airspace structure should be developed in line with European Airspace strategies. Thesestrategies acknowledge the general defence and security needs and aim at dedicating suYcient airspace formilitary purposes. The core principles for military use of European airspace include:

— Freedom to operate at any time in all areas.

— Special handling in particular for priority flights and for time-critical missions, but also for militaryaircraft whose equipment is not fully up to civil standards.

— Possibility of conducting uncontrolled VFR flights, including in managed airspace.

— Temporary airspace reservations for UAVs, in-flight refuelling, air combat training, high-energyflying and other activities incompatible with the normal application of the rules of the air as closeas practicable to the respective airfield.

— Airspace restrictions for activities not related to aviation, like the protection of areas of nationalinterest, air-to-ground firing ranges, air-to-air gunfire and missile firing areas etc.

12. The military need for airspace is determined on day-to-day basis by a number of factors such asavailable equipment, available personnel and meteorological conditions. SuYcient airspace must thereforebe available when conditions are favourable. The location of the airspace is also of vital importance, notonly with regard to cost eVectiveness but also the time needed for the transit to remote areas. If too muchtime is used for the transit, the time available for training will be inadequate, resulting in missionineVectiveness, which in turn requires that mission to be re-flown.

13. The MoD does however seek to distribute its aviation training activity as widely as possible acrossthe entire land and sea area of the UK in an attempt to minimise the environmental and noise impact thatthis has on the wider community. On occasion, flying activity is restricted geographically by the requirementto use military ground facilities or the necessary interaction with ground troops or maritime platforms withinstatic training areas; furthermore, military aircraft necessarily avoid major centres of population, designatedindustrial sites and conservation areas as well as avoiding major civil air routes and areas.

14. The adaptable and flexible capability to conduct diVering operational tasks is achievable only becauseof the specialist training and experience gained through the conduct of training activity within UK airspaceand over the adjacent seas. Current limitations in the fidelity of simulation and an inability to fully rehearsethe complex missions and interactions required between multiple aircraft, ground forces or othergovernment agencies continues to demand and justify the vital requirement for autonomous and semi-autonomous, non-synthetic training across the full airspace block. This essential activity necessitates flyingfrom low-level to high altitude, manoeuvring the aircraft using its full flight envelope in order to achievethe requisite variety of skills to enable UK military aircrew to conduct the broad spectrum of operations,throughout the world, as directed by the Government.

Summary

15. The FASOC describes how the UK seeks to develop both the core attributes of air power in orderto conduct actions to achieve, or contribute to, desired decisive campaign eVects. At home, air and spacecapabilities, working closely with OGDs will maintain national security by securing UK airspace andcountering novel asymmetric and conventional threats. Further afield, developing crises and the need toneutralise emerging terrorist and WMD threats around the globe will require rapid intervention by VeryHigh Readiness forces, notably air power elements. Air power oVers speed, deployability, reach andsustainability. Consequently, streamlined Joint training in relation to the new operational environment willbe fundamental, not only in maximising the utility and impact of air power, but also in making the best ofDefence assets.

To reiterate, in order to achieve these strategic goals the MoD needs access, now and in the future, tosignificant volumes of appropriately sized and sited airspace in the UK.

Response to Questions

1. What changes to the management of airspace could be required as a result of the additional airport capacityoutlined in the 2003 White Paper? Are the White Paper’s projections for increased passenger demand stillaccurate? Are all the measures to provide for increased passenger demand likely to be implemented?

(a) The White Paper calls for development of regional airports; this could place an unacceptableburden on the airspace management system. Most commercial air transport is reluctant to operateoutside controlled airspace and so this brings an increasing requirement for the establishment ofzones of controlled airspace around the airports and significant volumes of controlled airspace toconnect the regional airports to the main airways system. This reservation of airspace for acomparatively small number of air transport flights excludes other airspace users and couldseverely restrict the MoD’s ability to operate. The MoD contends that segregation of this activityis but one method of managing the integration and deconfliction of the contrasting requirements

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of airspace users. The MoD is fully engaged in the Airspace Safety Initiative in which theintroduction of new Air TraYc Services Outside Controlled Airspace and other initiatives arespecifically aimed at further assuring the safety of commercial air transport operations outsidecontrolled airspace. The last resort should be the establishment of controlled airspace.

(b) Although the MoD does not have suYcient knowledge to comment authoritatively on the veracityof the White Paper’s projections we would expect that the current economic diYculties could slowthe growth in passenger numbers; however, we would expect that it will inevitably pick up again.

(c) Similarly, having observed the significant diYculties encountered by recent and current large-scaleairspace changes during the consultation and post-implementation phases, it is highly likely thatairport and airspace development will be severely constrained or delayed.

2. Can safety be maintained as airspace is increasingly utilised? Is there a suitable interface between militaryand civilian arrangements for air traYc control?

(a) Inside controlled airspace the safety of any long-term or projected increase in the utilisation of aspecific area of airspace is determined by the stringently tested procedures and safety managementsystems in place. On a day-to day basis the capacity should be determined by a combination ofprocedures, agreements and ultimately flow control; accordingly, safety should be assured.

(b) Outside controlled airspace (Class G), the number, type and nature of aviation activity is morediYcult to predict. It is predominantly a “see-and-avoid” environment although widespread andsignificant assistance is available from a range of Air TraYc Services. This is the environmentwithin which the MoD conducts the overwhelming majority of its activity. Activity ranges fromlarge scale pan-Defence multinational exercises at all levels to the most basic of flying training.Class G airspace oVers unprecedented and essential tactical freedom and flexibility.

(c) An airspace strategy driven by the needs of commercial air transport will inevitably lead to theimposition of controlled airspace and the consequent loss of Class G airspace. This has the cleareVect of excluding non-commercial users from controlled airspace and thus constraining theMoD’s ability to train and operate. Of equal concern is that the reduced volume of Class Gairspace must still accommodate the existing and potentially increasing number of non-commercial users. Whilst the MoD is making stringent eVorts to ensure safety through the fitmentof technological safety nets such as collision warning systems, we have a growing concern thatClass G airspace is being “squeezed” with the potential for the collision risk to be increased.

(d) The MoD always endeavours to provide a balanced response to airspace change proposals thatimpinge on its operations in Class G airspace. UK airspace is a very finite resource and althoughan airspace change associated with a regional airport may seem reasonably benign in isolation, theMoD is becoming increasingly aware of the potential for a cumulative detrimental eVect on itsoperational eVectiveness. Accordingly, it is becoming increasingly diYcult for the MoD to reachacceptable compromises with regional developers.

(e) The current UK interface arrangements, not just for air traYc control but for Airspace Policy inthe round, between civil and military aviation authorities are excellent; arguably they are withoutprecedent and set a global benchmark. The secondment of MoD staV to the CAA is intended toensure, on a day-to-day basis, that DAP is able to call upon military advice and MoD views informulating national airspace policy. The following supporting, institutional and operationalarrangements are also designed to ensure proper representation of MoD interests:

(f) Supporting Arrangements. A number of documents underpin the inter-relationship betweenMoD, the Licence holder (NATS), other ATS service providers and the CAA.

— Directions to the CAA. The Directions given by the Secretary of State for Transport and theSecretary of State for Defence set out the CAA’s air navigation functions. The Directions givenunder section 66(1) of the Transport Act 2000 Act (the Act) constitute the formal statement of theresponsibilities of the DAP, in particular with regard to the promotion of safe, eVective and eYcientco-ordination of air traYc services through the JANSC; consultation arrangements (in particularwith the Secretary of State for Defence); and environmental obligations.

— CAA/MoD Memorandum of Understanding (MoU). The MoU details the basis on which the MoDprovides air traYc management (ATM) services to non-military airspace users on behalf of theCAA, the Licence holder, or otherwise in support of the joint and integrated arrangements.

— NATS/MoD Contract. Under this Arrangement certain ATM related services are provided byNATS to MoD on a commercial basis. The terms of the Contract also require NATS to reimbursethe MoD for performing some services that would otherwise be their responsibility as the ATCLicence holder.

— NATS/MoD Operating Protocol. The holder of the ATS Licence is required to draw up, inconsultation with the MoD, an Operating Protocol setting out the co-operative arrangementsthrough which a joint and integrated approach to the provision of ATM services will be developed,implemented and sustained.

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(g) Institutional arrangements include:

— CAA Board. The CAA exercises control of its constituent regulatory Groups through the CAABoard. The Director of Airspace Policy is an executive Member of the CAA. The Assistant Chiefof the Air StaV (ACAS) is a non-executive Member of the CAA and is the nominated Member fornational security for the purposes of Section 67 of the Act.

— Appointment of the Director of Airspace Policy. The Director of Airspace Policy is a Member ofthe CAA appointed by the Secretary of State for Transport. The nomination for the purposes ofSection 66 of the Act to perform on the CAA’s behalf its specified air navigation functions is subjectto the approval of the Secretary of State for Defence.

— Airspace Policy Committee. Policy oversight of the DAP is exercised through the CAA’s AirspacePolicy Committee which is a Committee of the CAA Board. The Director of the Air StaV providesthe MoD representation.

— Joint Air Navigation Services Council (JANSC). The constitution and functions of the JANSC aredetailed in an Appendix to the CAA Directions. The purpose of the JANSC is to overseearrangements for the joint and integrated provision of air traYc services. The Director of AirspacePolicy is required to convene and chair meetings at least six-monthly with representation from theMoD and the Licence holder; Air OYcer Battlespace Management is the MoD JANSC member.

— Classification of Airspace. In relation to airspace issues, the Directions require the CAA to seekMoD approval before implementing any expansion or change in the classification of airspace thatmight have an adverse eVect on operational capability.

— Airspace and Safety Initiative (ASI). The ASI is a joint CAA, MoD, NATS, AOA, GA eVort toinvestigate and tackle the major safety issues in UK airspace.

(h) Operational Arrangements. The CAA/MoD MoU documents the areas of operational interfacebetween the MoD and CAA. There are also a large number of airspace policy and aviationspectrum matters where dialogue between the MoD and the CAA will be required beforeimplementation is possible. This is facilitated through the secondment of MoD personnel to theDAP and participation in the many collaborative and consultative fora involving the CAA, MoDand other representatives of the aviation industry.

(i) The MoD provides expert participation at key UK and European airspace and air traYcmanagement policy fora. Furthermore, the NATS/MoD led Joint Future Airspace Design Teamhas enabled MoD consultation and involvement from the outset in NATS’ recent large-scaleairspace design and management projects.

3. Is the current approach to planning and regulating the use of UK airspace adequate? Would an AirspaceMaster Plan covering the period of the White Paper be beneficial? Would a piecemeal approach to individualdevelopments necessitate additional redesigns subsequently?

(a) The current approach to airspace planning and regulation is adequate. However, outwith the large-scale airspace changes initiated by NATS, other smaller (piecemeal) airspace changes or initiativesare based on specific and unrelated business cases. Whilst, in isolation these may solve a particularregion-specific problem inevitably there are knock-on consequences downstream and in adjacentairspace. Through its involvement in the Airspace Change Process the MoD seeks to provide animpact assessment based on a broad national airspace perspective taking into account the potentialknock-on eVects that a change may have in another part of the country. However, this assessment isstill reactive and competed without full knowledge of what other regional changes may be pending.Clearly, a strategic plan for the development and utilisation of UK Airspace is required that reflectsand balances the needs of all users framed by any strategic Government-set priorities.

(b) The MoD has contributed to the Future Airspace Study which we understood was intended toexamine airspace planning issues from a more strategic standpoint. However, it’s focus appearsto changed little from its original remit as the South East Airspace Study which concentrated onfacilitating the growth of commercial air transport in the South and South East of England. Therecently formed UK/Ireland Functional Airspace Block Airspace Design Working Group mayaVord an opportunity to examine airspace usage more strategically.

(c) The MoD would welcome and assist in the formulation of a DfT-led Airspace Master Plan. Sucha Plan should, first of all, determine the pan-Government priorities for airspace use and then reflectand balance the requirements of all airspace users not just commercial air transport. As set out inthe introduction the MoD is very clear on its strategic direction and the critical role that access toappropriately sized and sited airspace plays in our ability to deliver the Defence Aim. It is essentialthat the any Airspace Master Plan incorporates, from the outset, the MoD’s current and futureairspace requirements.

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4. How are the eVects and aircraft noise and emissions taken into account when changes are made to the useof airspace? Who should be consulted about such changes? How should the balance between conflicting interestsbe struck?

(a) The Airspace Change Process Guidance Document (CAP 725) provides comprehensive anddefinitive guidance on the consultation process, including environmental factors.

(b) Through the Airspace Change Process the MoD is able to review proposed airspace changes of allshapes and sizes and provide response and comment that can influence and inform the finaldecision. The MoD is content that historically this process has proved to be reasonably fair andequitable. However, the MoD is growing increasingly uneasy that a political imperative toaccommodate commercial air transport may sway the balance away from Defence needs; indeedthe focus of this Inquiry is a prime example.

(c) As a last resort Section 67 of the Transport Act 2000 enables the national security nominee on theCAA Board (ACAS) to have an issue referred to the Secretary of State for Transport if there isconcern that a decision could have an eVect contrary to the interests of national security.

5. How does the management of airspace in the rest of Europe aVect flights into the UK? Is there an opportunityto integrate our plans for changes to airspace management more eVectively with those of other Europeancountries?

(a) The management of airspace in each individual European State can aVect flights throughout thecontinent. Conditional Routes (CDRs) are a good example where a leg through one state may beopen, however it is closed downstream owing to a diVerent state having activity in a Danger Area.Pan-European airspace management, possibly in the form of a Functional Airspace Block shouldaddress this to some degree. All CDRs require alternate routes, therefore a flight will make itsdestination, however it may well not be along the most economic path; flights into the UK areaVected in the same way. The primary issue is how the flights are presented. If they are bottleneckedthrough a choke point owing to another State’s airspace management, then potentially there canbe sector overloads, delays and restrictions. This also places additional pressure on the UKstructure to find alternate means to ease the pressure. This could be requiring Areas reserved formilitary use not to be booked for certain periods. This is covered in the concept of Flexible Use ofAirspace; however, the situation can be forced upon the UK from other States’ actions.

(b) New systems are being developed for a more European view of airspace management. The UK,including significant MoD representation, is integrally involved in a forthcoming trial which seeksto improve airspace management and ATC flow management. The trial will incorporate a newlyestablished Military Liaison OYcer (MILO). The MILO will sit within the Central FlowManagement Unit to oVer advice on Pan-European military activity. Eurocontrol are developingnumerous other initiatives which are designed to facilitate integrated European airspacemanagement. In addition the development of a single European Aeronautical Informationdatabase and an updated Airspace Usage Plan should improve European airspace management.All of these developments are supplementary to current practices with our neighbouring states,such as the daily process with the French Airspace Management Cell and the UK/IrelandFunctional Airspace Block.

6. What opportunities are there to apply new techniques and technologies to reduce wasteful flying on indirectroutes and excessive “stacking” while planes wait to land? How can the potential of any such opportunities bestbe realised? Could environmental benefits be gained as a result of such improvements?

(a) This is not an area where the MoD can oVer significant authoritative comment. However, we areaware that direct routing throughout UK airspace for overflights is a design concept ongoing atpresent. Despite obvious benefits to the Airline Operators the overall impact needs to be carefullyand thoroughly assessed. Direct routing across the Atlantic to mainland Europe wouldundoubtedly pass directly through the North Sea Managed Danger Areas. National policy andstrategy would need to be reviewed for priorities and protocols, and it is imperative that the MoDis engaged from the outset in the design process.

7. In relation to the redesign of UK airspace, is the allocation of the roles and responsibilities of each of theinterested parties-Department for Transport, the CAA, airport operators, NATS, etc-appropriate and clearlyunderstood? Are the structures of the parties appropriate for undertaking the roles that they should play?

(Firstly, it is of concern that the MoD is not listed above as a key interested party.)

(a) The roles, responsibilities for Airspace and Air Navigation spring from the Transport Act 2000and are further described in the CAA’s Air Navigation Directions. The Airspace Charter (CAP724) and Airspace Change Process (CAP 725) provide another level of detail again. The roles andresponsibilities and processes to be followed by organisations involved in airspace design are

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Ev 114 Transport Committee: Evidence

comprehensive and clear. The MoD seconds a significant number of experienced personnel to theCAA to ensure that on a day-to-day basis DAP is able to call upon military advice and MoD viewsin formulating national airspace policy.

8. Do airspace management considerations delay the planning processes in relation to airport developmentproposals? How will airspace management considerations be taken into account by the proposed newInfrastructure Planning Commission and the relevant National Policy Statements on airport planning?

(a) Under the Airspace Change Process airspace management considerations are an integral andessential part of any airport development proposal and therefore the time taken to satisfy thatrequirement cannot be considered as a ‘delay’. The MoD is not familiar with the requirements ofthe Infrastructure Planning Commission however, we would expect the Airspace Change Processto be followed.

9. What could be the implications for smaller airfields, recreational flying and helicopters of changes toairspace management to enable safe and eYcient increases in capacity at the UK’s major airports? How shouldan appropriate balance between conflicting priorities be determined?

(a) The MoD would be interested to learn which airports in the UK the Transport Select Committeewould classify as “Major”. The MoD considers any airport that would currently meet a majorclassification already has its operation fully safeguarded by the provision of significant volumes ofcontrolled airspace including the London and Scottish TMAs and the associated Airway andUpper Air Route structure.

(b) Any aspiration to initiate and develop a greenfield “major” regional airport operation away fromthe existing controlled airspace structure and to provide safety and eYciency by the establishmentof exclusive controlled airspace will have significant and almost certainly unacceptableconsequences for existing airspace users in that region. Controlled airspace should only beestablished when it is absolutely essential taking into account the minimum volume of airspacenecessary and proposed times of operation.

(c) On the principle of “Polluter Pays” it is for sponsor of the changes to put into place measures thatmitigate any consequences of their changes. If controlled airspace is established there should be agreater requirement for the change sponsors to demonstrate that they are able to facilitate accessby other users. Accordingly, as part of the approval the CAA needs to ensure that airports providefully resourced ATC arrangements so that only operational/safety constraints limit other users’access to the airspace and not “controller capacity” or equipment limitations.

(d) Furthermore, when deciding to grant an airport controlled airspace the CAA should consider thepreviously described “squeeze” eVect that it will have on other Class G users and require airspacechange sponsors to specifically address this through the provision of an ATS for ac in the vicinityof their operation. In line with Flexible Use principles, where necessary the times of activation ofcontrolled airspace should be limited to peak flow times to strike a balance between the varioususers’ requirements.

(e) The initial balance of conflicting priorities should first and foremost be in line with nationallyagreed strategic priorities ie Government aspirations to develop a region economically and a keyenabler being the development of an air link set against national security interests. Once that isagreed, tactical and specific case-by-case conflicts can be resolved by collaboration and arbitrationbut set within the strategic guidelines.

10. Will it be possible to recruit and train staV in order that airspace changes can be implemented in parallelwith additional airport capacity?

(a) Increases in airport capacity must be made with appropriate resources, especially qualifiedpersonnel. A programme of airport expansion without adequate resources will not enable theexpected increased capacity to be realised without jeopardising safety. Moreover there could be anexpectation (misplaced) that any gap in capacity causing safety concerns such as a lack of radarcapability would be met by the MoD.

11. Who should fund airspace changes? Is there likely to be enough funding to undertake the redesign requiredto bring about the necessary additional airspace capacity?

(a) There are parallels with other elements of national transport infrastructure eg roads and rail. Forthe national aviation infrastructure such as en-route airspace, revenue raised from navigationcharges should be used to fund work in support of maintaining and developing that network.Similarly, any organisation profiting directly from that network should be appropriately “taxed”.For regional airports, the airport/operators should fund the work. The scale, complexity and risks

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of the project together with ongoing costs of providing suYcient ATC staV would then ensure thatthe decision to proceed would only be taken if there was a high level of confidence that theanticipated traYc increases would happen.

October 2008

Memorandum from Chiltern Countryside Group (AIR 09)

The Chiltern Countryside Group represents people who live, work and enjoy leisure pursuits throughoutthe Chilterns.

The Steering Group comprises aviation and transport consultants, commercial pilots and professionalsin technology, media, healthcare & education.

Summary of Evidence

— Current economic conditions render the projections of the 2003 White Paper inaccurate andunlikely to be fulfilled. The time should be used to address current constraints such as Holds, whichimpact on highly congested airspace in the SE.

— Safety will be compromised if more aircraft movements are allowed in already over-crowdedairspace such as TCN in the SE.

— Current approach to planning use of UK airspace is piecemeal and thus will require redesigns atregular intervals. A wider picture with a “can do” approach would be more economical &potentially more environmentally beneficial in the longer term.

— NATS does not have clear understanding of Government guidelines, particular with regard tooverflights of AONB and population.

— Review should be made of all airports with 24 hour operating licences and serious considerationgiven to the adverse eVect these have on the population overflown.

— Funding should be made available to commission the development of noise measuring metrics thatcorrectly take into account background noise, so that relevant, accurate data can be supplied tothe public and other interested bodies.

— Consultations should be carried out with wider access of information to the general public, MPs,Councils, Conservation and residents groups. NATS should be prepared and informedappropriately so that questions from the public & organisations can be answered fully before theclosing date of consultation. The public should be given an amount of time in which to respond,relative to the length of time taken for preparation of the consultation.

— Greater consultation should be undertaken with interested bodies, whilst the consultativedocument is being prepared. Commissioned agents need to be transparent, accessible and open topublic scrutiny.

— Review of procedures for short haul flights, holding procedures and their location, the use by ATCof Continuous Descent Approaches & the impact of PR-NAV on residents beneath these routesshould be undertaken.

— Clear definition of the roles and responsibilities of interested parties, eg CAA, NATS, DfT shouldbe given. The general public do not have confidence that NATS can act as an unbiasedcommissioned agent for Consultation & as the operator of any changes. An independent body, notthe CAA, should make the final decision on any changes.

— Right of appeal should be more accessible without a costly Judicial Review; the appointment ofan Ombudsman would fulfil an important role in any necessary arbitration.

— Any redesigns of airspace must be managed safely but also minimize environmental impact,through ongoing dialogue during the design change process.

— If further airport development has to happen, this would be more eVective at regional airportsoutside the congested SE.

— As additional airport capacity is currently not required, a wiser & more appropriate decision wouldbe to review changes which could reduce & simplify the workload of ATC, without increasingpollution to residents and the environment.

— Funding should be provided by those who will benefit from the changes, ie the airlines and airportoperators.

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Development of Points Covered Above

1. Due to the current global economic situation and particularly, the price of oil and turbulent financialmarkets, the projections of the 2003 White Paper are not accurate and will not be fulfilled. Thereforemeasures which had previously been considered necessary to provide for these are no longer required. Timeshould be used to address current issues, not future ones, eg present specific constraints in TCN area ofairspace, such as the location of the Heathrow holding beacons.

(ref: section 0.5, 0.8, 2.10 CCG Technical Report 1; sections 2, 4 CCG Technical Report 2.)

2. Safety will be compromised if more aircraft movements are allowed in already congested areas such asthe TCN airspace. Safety will also be compromised if airports in densely populated areas such as Heathroware expanded with additional flights and runways. As aircraft are most proximate to each other during takeoV and approach to landing, developing airports in conurbations increases risk to resident populations &places greater stress upon ATC and pilots.

(ref: section 2.1 CCG People’s Response doc; section 1 CCG Technical Report 2.)

2.1 CAP772 identifies a 13km Safeguard around designated airports in which these airports can influenceplanning and land use to minimise birdstrikes. The aviation industry has a responsibility to minimisebirdstrikes. Therefore the design of long distance flight paths at 3,000 feet above ground level outside the13km Safeguard erodes this safety measure, as aircraft would be flying only a few hundred feet above whatis currently acceptable within the Safeguard.

3. The current approach to planning use of UK airspace seems to set limits on what is possible—thereappears to be no “can do” ethos or even, “let’s see what can be done”. The lack of a holistic approachinevitably requires continuous redesigns. Serious consideration should be given to a wider picture approachwhere historical operational constraints which impact on several areas, such as holding procedures, can bereviewed for greater benefit. The concept of “winning a battle but not the war” seems relevant to the currentapproach. An Airspace Master Plan with appropriate consultation at all levels, including environmentalbodies at the initial stage, could be beneficial.

(ref: section 0.5, 2.8, 2.9, 4.4 CCG TR 1; section 2 CCG TR 2.)

4.1 We can only speak for the TCN Consultation on this subject. The consequential eVects of aircraftpollution (visual, aural and air quality) upon valued landscapes, rural market towns and settlements was notpriority. NATS does not appear to display a clear and consistent understanding of how to interpret currentGovernment guidelines as given in CAA Publication 725—Guidance on the Airspace Change Process, theCountryside and Rights of Way Act 2000, Department of Transport: Guidance to the CAA onEnvironmental Objectives Relating to the Exercise of its Air Navigation Functions 2002, nor EU Directive2002/30.

(ref: sections 2,3,4 CCG People’s Response doc.)

4.2 No consideration was given to the potentially extremely detrimental eVect on mental and physicalhealth of night operations from UK airports with 24 hour operating licences. Such operations are onlynecessary in emergency; embargo, or strict limits, should be imposed on flights during the EC recognisednight time hours of 23.00-6.00am. The adverse eVect on residents’ health will place additional burdens uponHealth Care and Social Services, at taxpayers’ expense. Benefits, if any, will be limited to airlines. Noconsideration was given to the possibility of increased air traYc.

(ref: sections 2.8, 3.4 CCG People’s Response doc.)

4.3 Worst case scenario figures on height levels were given in a form, meaningless to residents living undercurrent and projected flightpaths, as this gives permission for worst case low level flights & reduces the rightsof the resident when disturbed by noise. Figures and facts should be accurately and consistently presented,eg height levels should be measured from the same start point throughout the Consultation document.Measurement should be made of background noise, as it is scientifically recognised that the same volumeof noise introduced into a tranquil, silent environment will be far more intrusive, than against a backgroundwhich is already noisy. Recent studies have shown that people today have lower tolerance levels of noise thatin the past, which reflects the increasingly noisy society in which we now live. If no such measurements arecurrently available, these should be commissioned and funded adequately so that proper data can besupplied to the public and other interested bodies.

(ref: section 3.4, 3.5 CCG People’s Response doc.)

4.4 Proper public consultations should be carried out with public meetings organised by thecommissioned agent (eg NATS); individual mailshots should be sent out to every home within areas of greatchange ie. those where routes/holding procedures are being introduced for the first time, or considerablymodified. Knowledge of existing routes/holding procedures, & therefore current impact, should beincorporated into new designs, so that a full appreciation of the whole, 24 hour, 365 days pa impact forresidents is part of the plan.

(ref: section 1. CCG People’s Response doc.)

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Transport Committee: Evidence Ev 117

4.5 MPs and Councils should be properly briefed by professionals; the commissioned agent should haveprofessional staV available to present changes and give full briefings at Council/Public Meetings and to local& national resident/environmental bodies and charities.

(ref: section 1, CCG People’s Response doc.)

4.6 SuYcient staV, trained and knowledgeable about the consultation, should be employed by thecommissioned agent so that questions from the public and organisations can be answered fully by phone,e$mail or letter before the closing date.

(ref: section 1, CCG People’s Response doc.)

4.6 The time-scale of the consultation should reflect the complexity of the changes ie if the changes havetaken four years to prepare, then 25% of that time would seem an appropriate amount for the public torespond.

(ref: section 1, CCG People’s Response doc.)

4.7 The area’s interested bodies eg County Councils, Conservation Boards, environmental and residentgroups should be more thoroughly consulted when the Consultation is being written, so that localknowledge can be utilised and particular issues addressed, thus minimising opposition and conflict afterpublication of the Consultation document.

(ref: section 1, CCG People’s Response doc.)

4.8 MPs and Councillors should have time to acquire the necessary information to brief their constituentsthoroughly, seek their views and if appropriate, set up Working Parties within their constituencies orboroughs. Elected representatives should be engaged in discussion at the earliest opportunity, together withcharities and other environmental bodies with key interests either nationally, or within the specific area. Thewidest possible publicity should be undertaken to ensure that the public gains access to relevant facts &information. Commissioned agents need to be transparent, accessible and open.

(ref: section 1, CCG People’s Response doc.)

4.9 To achieve a reasoned balance between conflicting interests—if the above suggestions were carriedout in good time at the right stage, then many of the conflicting interests could be resolved by discussionand negotiation. If this happens, then a balance between conflicting interests is more likely to be achieved.

5.1. Arrival and en-route holding delays could be minimised by ensuring that short haul departures areco-ordinated so that landing can be achieved without delay at the destination airport. This would reduceflight times, fuel and emissions, in line with current & projected European initiatives.

5.2 Constant Descent Approaches should be the norm and a primary ATC objective, not withdrawnunless exceptional circumstances prevail. This would minimise disturbance for those residents living closeto airports. Numbers of flights should be reduced to a position where holding is not necessary, or can beaccomplished at higher flight levels.

5.3 Whilst PR-NAV can have the advantage of keeping aircraft within a tight routing pattern, this is, initself, extremely disadvantageous for residents living underneath the PR-NAV route. This is of great concernfor mental and physical health if residents are aVected by all flights, regardless of wind direction and if theairport concerned holds a 24 hour operational licence. This scenario would apply to some residents underthe original proposals of the TCN Consultation. Greater consideration must be given to their detrimentaleVect on residents if it is intended that PR-NAV routes become the norm.

(ref: sections 3.4, 3.5, 3.6, section 4 CCG TR 1.)

5.4 Holding procedures should be redesigned to cause the minimum of disturbance to residents. Even at7,000–10,000 feet aircraft are very audible, especially in rural tranquil areas, or at night. Any increase forholding that can be achieved brings environmental benefits as it significantly reduces fuel-burn, noise andpollution.

(ref: section 4, CCG TR 1, Proposals CCG TR 2.)

6. The roles and responsibilities of the interested parties are not clearly defined. The general public do notunderstand the relationship between DfT, NATS, CAA and airport operators. The public, quite rightly, findit very diYcult to believe that redesigns and consultations are unbiased when 41.9% of NATS is owned bya consortium of airlines and the rest by Government. These airlines naturally demand maximum use ofairspace with scant regard for the environmental impact. The relationship between NATS and CAA shouldbe more clearly separated. NATS, who are responsible for the changes, should not be commissioned todesign them and the final decision should not rest with the CAA, but with an independent body. The generalpublic does not understand what role the DfT play in consultation.

(ref: section 1.5 CCG People’s Response doc.)

6.1 The public, or other aVected bodies, should have right of appeal, which does not involve a very costlyJudicial Review. EVectively, the cost of such Court action precludes this from any but the most wealthy,which is an unfair situation. If an Ombudsman was appointed to look at individual and collectivecomplaints, this would not only ensure that only serious concerns were raised, but would also provide thepublic with a financially realistic legal channel in which to do this.

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Ev 118 Transport Committee: Evidence

7. The redesigned airspace has to be managed safely and eVectively to minimize environmental impact.Unless this can be achieved, redesigns are valueless. On-going dialogue between management and designersshould be in place throughout the design change process.

8. If further airport development has to take place, greater consideration should be given to regionalairports and their associated transport infrastructure, outside the already overcrowded South East.

9. As additional airport capacity is currently not required, it would seem a wiser & more appropriatedecision to fund research & re-design into those changes such as Holds, which can reduce and simplify thework load of ATC, rather than recruit and train staV who may not be required in the foreseeable future.

10. Funding should be provided by those who are going to benefit from the changes. As the changes willnot directly benefit the general public, funding should not be drawn from public taxes.

References

1. People’s Response to the NATS TCN Consultation, published Chiltern Countryside Group June 2008.

2. Technical Report 1: Response to NATS TCN Consultation, published Chiltern Countryside GroupJune 2008.

3. Technical Report 2: Response to Interim Feedback Report NATS TCN Consultation 2008, publishedChiltern Countryside Group September 2008.

October 2008

Memorandum from Marilyn M Fletcher BSc PhD (AIR 10)

Summary

(a) As airspace is increasingly utilised, there is pressure to design flight paths that occupy low-altitudeair space instead of allowing aircraft to climb. This causes increased noise and visual pollution,and increases the potential for birdstrike.

(b) Large high-flying birds are increasing in number in the UK, including raptors (Red Kite andBuzzard) and geese species.

(c) An increase in the population of large high-flying birds and air traYc, particularly if flight pathsare designed below 3,000 feet agl (above ground level), increase the risk of birdstrike.

(d) Damage to an engine at low altitude and not in the vicinity of an airport may not allow suYcienttime or space for the aircraft to recover or to make an emergency landing, resulting in a crash. Therisk factors (aircraft and large high-flying birds) are predicted to increase each year.

A directive should be considered presuming against long distance flying at 3,000 feet amsl (abovemean sea level).

(e) Currently there is a 13km Safeguard (CAP772) around designated aerodromes in whichaerodromes can influence planning and land use decisions in order to minimise birdstrike. Theaviation industry is dependent on the Safeguard to help minimise birdstrike.

Designing long distance flight paths below 3,000 feet agl outside the 13km Safeguard erodes thepresent safety arrangements: aircraft would be flying for long distances outside the Safeguard, yetonly a few hundred feet above what is currently considered acceptable within the Safeguard.

(f) Clarification of para. 4.4 CAP772 is required.

(g) The recent update (Sept 2008) of CAP772 did not include identification of Red Kite and Ravenfor bird controllers at airports. This may need rectifying.

(h) The topography of land over flown at low altitude is not currently included in the “Guidance tothe Civil Aviation Authority on Environmental Objectives Relating to the Exercise of its AirNavigation Functions”. This should be reviewed.

(i) At present there is a lack of clarity in the interpretation of paragraph 45 of “Guidance to the CivilAviation Authority on Environmental Objectives Relating to the Exercise of its Air NavigationFunctions”. This will result in flight paths being clustered over National Parks and Areas ofOutstanding Natural Beauty (AONBs).

(j) The law is clear with regard to the CAA’s duty to the Countryside and Rights of Way Act (CROWAct) 2000 (Schedule 1 Part 11 Section 14e). However, NATS has disputed its own duty to theCROW Act. This should be clarified.

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1. Low-altitude flying increases the potential for birdstrike:

(a) As airspace is increasingly utilised, there is pressure to design flight paths that lie at lower altitudesthan is currently the case. In order to maximise airspace, it is envisaged that the development oflow-altitude flight paths may be permitted that continue for long distances from departure airportsinstead of allowing aircraft to climb rapidly. Such development will cause increased noise andvisual pollution over large areas.

(b) As a Zoologist, university lecturer in Biological Sciences and member of a local conservation group,I would like to draw your attention to the potential for increased birdstrike if relatively longdistances of low-altitude flying are designed. Flight paths designed for long distances below 3,000feet agl are of greatest concern. In the USA, it is recognised that the height at which nearly allbirdstrikes occur is below 3,000 feet agl (US Federal Aviation Administration Wildlife HazardManagement Manual 2005). Although care should be exercised in comparing continents, up to3,000 feet agl. is also the height at which raptors can generally be found in Britain (details below).

(c) The increasing pressure to design relatively long distances of low-altitude flying is exemplified byproposals in the recent TCN Consultation. Here NATS has proposed that aircraft can fly at 3,000feet amsl. along half the length of the Chiltern Hills.

The Chilterns are formed by an escarpment intersected by several river valleys, which in eVectdivide it into a series of plateaux. These lie at 600 to 700 feet amsl. Thus if the proposals go ahead,aircraft will be flying 2,300 to 2,400 feet above the ground along the lengths of the plateaux. Thiswill occur up to twenty miles from the departure airport, Luton.

(d) I can find no directives which alert NATS to the presumption that flying for long distances below3,000 feet agl increases the potential for birdstrike. The Chilterns is a designated AONB one ofwhose functions is to encourage conservation/growth of local fauna. Flying 2,300 to 2,400 feetabove the ground for relatively long distances increases the chance of birdstrike.

(e) Large raptors (Red Kite and Buzzard) and geese species (particularly Canada Geese) are increasingin numbers nationally:

(i) “Red Kites Soar in 2008” is one of the RSPB’s “Top Stories”.(1) The re-introduction of kite(amber conservation status) into the Chilterns and elsewhere in the UK is a huge success inconservation terms.(2)

In the Chilterns kite are increasing rapidly: in 2005 there was a total population of 250 breedingpairs (1,500 individuals including juveniles and non-breeding adults).(3) The population ofbreeding pairs has doubled in just three years and is now in excess of 500 (Southern England RedKite Group). Extrapolating from this, the total number of individuals in the Chilterns in 2008 maybe 3,000.

The kite population in the Chilterns is currently at its most concentrated around Stokenchurch/the M40, which was its original re-introduction site in 1989. The Red Kite has yet to exploit itsdistribution to its full potential. This is because kite, like other birds of prey, have an inbuilttendency to breed close to where they were reared, which means that they are relatively slow tocolonise new areas.(2)

However, their territory is spreading.(3) Red Kite can be seen every day (albeit in considerablysmaller numbers, as yet, than a few miles further South) in the area proposed by NATS for aircraftto fly below 3,000 feet agl.(3)

Kite are readily adaptable.(2) Providing persecution is minimised, it is thought that there is noreason why the Red Kite should not become a familiar sight over much of lowland England.(3)

(ii) The Buzzard is increasing rapidly now, and is predicted to do so in the long term.(4) It hasspread into the south and east of Britain. Buzzards are apparently attracted to Red Kite. It islikely that they will continue to populate areas where kite are present.

(iii) Canada Geese have undergone a dramatic increase in population (CAA’s Safety RegulationGroup’s “Large Flocking Birds: an International Conflict between Conservation and AirSafety”).(5) Other species of geese are also increasing in the UK.

(iv) Ravens are increasing in lowland England.(7) Again, they seem to be attracted to kite.

(f) The wingspan range of these species is 4 to 5.5 foot. In the case of an aircraft engine engulfing oneof them, the Canada Goose would probably do the most damage, being the heaviest. However, theraptors and Raven would also cause considerable damage, their long wings and body weight notbeing dissimilar, in terms of potential damage, to the long-limbed Heron. The Heron is thought tobe the species ingested by a commercial aircraft in March 2007 causing an emergency landing atManchester Airport.(8)

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(g) The height that raptors fly is dependent on the production of thermals.

Buzzards fly at an average of 1,300 feet in the UK, but can be found over 3,300 feet on warm cleardays, or even higher.(9)

In general, Red Kite forage at a lower height than Buzzards, quite often fairly close to the ground.However, kite also like to soar high, possibly when making their way to foraging areas. A studyin Northern Germany on the maximum height to which raptors fly found Red Kite 3,300 feetabove ground level, compared with Buzzard at 4,300 feet agl.(10)

Kite have been struck by military and light aircraft in the UK,(2) presumably as have other speciesdiscussed here, although I do not know at what height. Booker Airport, High Wycombe, hasapparently had problems with kite.

I could find no references to the altitudes that Ravens fly. However, Ravens are attracted to RedKite accompanying them in flight, “spiralling upwards together until disappearing from view”.(11)

Canada Geese can fly extremely high when migrating (9,000 feet), although most in the UK, Ibelieve, are non-migratory. Canada Geese fly in small flocks within the UK to exploit food sources/nesting areas/habitat, and to form winter flocks on lakes and reservoirs. I do not know how highthis species flies on such trips. The projected increase in wet summers and the resulting floodingwill presumably further increase available habitat, and therefore, probably, the population ofthis species.

Large reservoirs (eg Tring, Bucks) sometimes attract flocks of nationally-rare varieties of migratinggeese. Are these monitored?

Some swan species fly at high altitude during migration (Whooper Swan—a UK species). I do notknow how high Mute Swans fly.

(h) The greatest danger to aircraft is the presence of large flocking birds because of their potential tocause multiple engine failure resulting in a catastrophic air accident. Canada Geese and other waterbirds fly in small flocks (skeins). Raptors and ravens attract one another, and form small aerialsocial groups.(11)

(i) Most cases of birdstrike currently occur in the vicinity of an airport, where an emergency landingcan take place if a single engine is involved.(8) In contrast, an aircraft on a low-altitude flight pathwith birdstrike to a single engine may be tens of miles from an airport. Such damage to an aircraftat low altitude and not in the vicinity of an airport may not allow it suYcient time and space torecover or to make an emergency landing, resulting in a crash.

(j) Safeguarding

Currently there is a 13km zone or Safeguard, around designated civil and military aerodromes(CAP772 Birdstrike Risk Management for Aerodromes).(12) The Safeguard is an area over whichairports can influence planning and land management decisions which may attract species liableto cause birdstrike.

CAP772 states “The 13km circle is based on a statistic that 99% of birdstrikes occur below a heightof 2,000 feet, and that an aircraft on normal approach would descend into this circle atapproximately this distance from the runway.”

(i) Caution should be exercised with the above statistic. The increase in large high-flying birds, andthe pressure to increase long distance flying below 3,000 feet agl. will aVect this.

(ii) The description of the Safeguard is not clear. However, as I understand it, the Safeguard canbe described as a short cylinder of airspace; its radius is 13km; its height is 2,000 feet; at thecentre of one of its bases lies the aerodrome. This cylinder of airspace is where aircraft arebelieved to be most likely to expect birds.

It is surely, then, not acceptable practice for aircraft to fly outside the Safeguard for long distancesat 3,000 feet amsl., where they may encounter raised ground at several hundred feet amsl. Forexample, in the Chilterns, aircraft will be flying a long distance from the Safeguard at only 300 or400 feet above what is considered acceptable in the Safeguard, and without any of the protectionoVered by the Safeguard.

Action: Improve wording of CAP772 “…an aircraft on normal approach would descend into thiscircle at a height of 2,000 feet at approximately 13km from the runway.”

Caution: The aviation industry is dependent on the Safeguard (CAP772) to help minimisebirdstrike. Designing long distance flight paths below 3,000 feet agl. outside the 13km Safeguarderodes the present safety arrangements: aircraft would be flying for long distances outside theSafeguard yet only a few hundred feet above what is currently considered acceptable within theSafeguard.

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(k) CAA up-to-date?

The CAA states “it is fully cognisant of the safety risk to aircraft operations posed by birdstrikes”.CAP772 is concerned with birdstrike risk assessment and mitigation and is aimed at aerodromes.Species identification is described as being “essential” by the CAA (para. 5.1) in order to minimisefurther risk.

However, among the 33 species which bird controllers at airports are trained to identify, Red Kiteand Raven are not mentioned. This is despite the chapter on species identification being publishedonly last month and the increase in kite as an RSPB “Top Story”. It is obviously important for theCAA to be aware of recent changes in the UK bird population.

Action: Consider amending CAP772 to include Red Kite and Ravens.

(l) An increase in air traYc (particularly if flight paths are designed below 3,000 feet agl) and an increasein the UK population of large high-flying birds increases the risk of birdstrike. Flight paths shouldbe designed to take aircraft above 3,000 feet agl. as soon as possible. Aircraft should not be keptdown for tens of miles in a stratum of airspace far from the airport vicinity where they willoccasionally encounter large birds. The projected increase in air traYc (for example onecommercial plane every six minutes at peak periods over the Chilterns at 2,300 to 2,400 feet agl)makes such an encounter a possibility, and the risk factors (numbers of aircraft and large high-flying birds) are predicted to rise each year.

Action: A directive should be considered presuming against long distance flying at 3,000 feet amsl.

2. Topography

(a) The topography of land over flown at low altitude should be considered for inclusion in the“Guidelines to the Civil Aviation Authority on Environmental Objectives Relating to the Exerciseof its Air Navigation Functions”. Topography is not currently included in this document, whichwas published in 2002 and has not been altered since. Suggested wording:

Action: “Local topography should be taken into consideration when designing flight paths at lowaltitudes in controlled airspace, in order to minimise the impact on the environment of low flyingaircraft.”

3. Countryside and Rights of Way Act (Crow Act) 2000 section 85

The law is clear with regard to the CAA’s duty to the CROW Act 2000 Section 85: the CAA’s duty isembedded in the act (Schedule 1 Part 11 Section 14e). However, NATS has disputed its own duty to the Act.(TCN Consultation Initial Feedback Report Section 26.7).(13)

Action: It is not logical or practical for one organisation involved in airspace change to be subject to theCROW Act 2000, and for another to declare that it is not. This should be clarified.

4. Paragraph 45—“Guidelines to the CAA on Environmental Objectives Relating to the Exercise of itsAir Navigation Functions” states:

“Government policy will continue to focus on minimising over-flight of more densely populatedareas below 7,000 feet. However, where it is possible to avoid over-flight of National Parks andAONBs below this altitude without adding to the environmental burdens on more denselypopulated areas, it clearly makes sense to do so.”

(a) A letter from the Minister of State for Transport, Rosie Winterton, to the Chilterns ConservationBoard (2 August 2008) clarifies the interpretation of paragraph 45. She states that “more denselypopulated” and “congested” are interchangeable. This interpretation means that in designingflight paths, over-flight of congested areas (large towns and cities) should be minimised below7,000 feet.

(b) In contrast, NATS has interpreted paragraph 45 in the comparative sense of “more denselypopulated” to mean that flight paths should be sited so aircraft over-fly wherever fewer people live.This is demonstrated in the recent TCN Consultation where NATS believes it is followinggovernment guidelines by moving the centre-lines of flight paths for Westerly and Easterly LutonDepartures bound for the SW from a position over the small market towns of Princes Risborough(population 8,000) and Wendover (population 7,000) to a position over the Chilterns AONB.These small towns lie at a lower altitude than the Chilterns and cannot be described as“congested”. Nevertheless, because the Chilterns route is less densely populated than the existingWendover/Princes Risborough/associated low lying countryside route, NATS believed, and still dobelieve (TCN Initial Feedback Report para. 7.2.3), that the proposed flight paths over theChilterns will now comply with government guidelines. This move will result in the proposed flightpaths conflicting with other air traYc, so that aircraft on the proposed flight paths will need toremain at lower altitudes for far longer than at present (including the potential for Wendover andPrinces Risborough to be over flown at a lower altitude than at present during oV-peak periodseg. night-time) (Figs. 8,9,16 and 17 NATS TCN Consultation Document).(14)

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Ev 122 Transport Committee: Evidence

(c) If the reader interchanges the word “congested” for “more densely populated” (as stated by theMinister of State), it is clear that in moving the flight paths over the Chilterns AONB, NATS hascontravened paragraph 45 of the government’s guidelines.

(d) The inevitable result of pursuing the policy of over-flying less densely populated areas interpretedin the comparative sense, as NATS has done, is that as airspace is increasingly utilised, flight pathswill become clustered over National Parks and AONBs. Because there are restrictions on theamount of building that can be carried out on these designated lands, they are inevitably lessdensely populated.

The aggregation of flight paths over National Parks and AONB’s is clearly not what the governmentintends.

Action: Clarification of paragraph 45 by inserting the word “congested” (as is used in paragraph46) for “more densely populated”.

Finally, I am not an ornithologist. The information provided should be verified. Marilyn M FletcherBSc PhD

October 2008

References(1) http://www.rspb.org(2) Carter (2007) The Red Kite, Arlequin Press.(3) Carter and Whitlow (2005) Red Kites in the Chilterns, English Nature and the Chilterns ConservationBoard.(4) http://www.bto.org/birdtrends2007/wcrbuzza.htm(5) http://www.caa.co.uk/docs/1437/srg—acp—00018-01-030303.pdf(6) http://www.bto.org/birdtrends2007/wcrmutsw.htm(7) http://www.bto.org/birdtrends2003/wcrraven.htm(8) http://uk.youtube.com/watch?v%hpSuPDWswNs(9) http://www.rspb.org.uk/advice/expert/previous/buzzard.asp(10) Kusters and Scheller (1998) Birdstrikes with Military Aircraft and Flight Altitudes of Raptors inGermany, International Birdstrike Committee 24/WP 26.(11) http://www.birdsofbritain.co.uk/features/red-kite2.asp(12) http://www.caa.co.uk/docs/33/CAP772.pdf(13) http://www.consultation.nats.co.uk/uploads/Initial%20Feedback%20Report%2022%20July%202008(1).pdf(14) http://www.consultation.nats.co.uk/uploads/TCN-PartF-CHILTERNS-and-LUTON-20march08.pdf

Memorandum from Ashmansworth Parish Council (AIR 11)

Summary

Our most immediate impressions of CAA and the manner in which they work are related to their handlingof the manner in which they have handled a request by NATS to extend airspace in Southern England. Inaddition, this has led us to examine their approach to similar cases elsewhere. As a result we have developedthe following concerns which we would like your committee to consider:

— National and European Legislation provides demands, including environmental aspects, thatCAA must obey in choosing air traYc routes. It is submitted that CAA has not always paidsuYcient attention to this.

— As indicated in the announcement of this Enquiry, CAA has a close relationship with NATS. It issubmitted that this relationship is too intimate in that it appears that CAA nearly always supportany proposal from NATS, irrespective of the merits of the individual case. It appears that evidencefrom other sources, even that which is developed by environmental specialists, is downgraded andlargely dismissed.

— When proposing changes to airspace routings, NATS usually holds an enquiry and on the basis oftheir results, requests CAA for approval of the changes. It appears that NATS frequently fail toconduct the enquiry in the manner laid down by CAA and fail to take any account of key issuesraised in the enquiry. CAA seem to gloss over errors in the NATS’ process and always appear tosupport NATS’ conclusions. This results in respondents to that enquiry wasting their expectations,time and money in preparing a case.

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— There is no reasonable, aVordable appeal process against decisions of CAA.

— Details of some of these shortcomings were given by our MP Sir George Young in the adjournmentdebate on 19 November last year.

Submission

1. The UK is one of the most crowded countries in the world and population densities in our cities arehigh. However, we are blessed with a limited number of tranquil areas, especially those designated asNational Parks and Areas of Outstanding Natural Beauty, where pollution and particularly noise levels, aremuch lower and highly prized by those who visit or live there. An aircraft flying over a very quiet area maygenerate levels of noise suYcient to upset people whereas the same level of noise might pass totally unnoticedover a city. There is legislation in place to protect such areas but CAA fail to take account of ambient noiselevels of each area. When considering the relative impact of noise over diVerent routes, currently tranquilareas, especially National Parks and AONBs, must be given priority. The most sensitive areas should ideallybe avoided altogether.

2. NATS is a commercial company with clear targets to meet. They generally perform well in meetingtheir own objectives, but we rely on them being regulated fairly by CAA, since there may be a conflictbetween commercial desires and environmental concerns or national well-being. For many years (from thecreation of CAA in 1972 until 2001), NATS was part of CAA but now they have been given clearly distinctroles. However, it is felt that there are still considerable close relationships between staV in the twoorganisations. This results in a natural tendency for CAA to support any request from NATS. CAA shoulddemonstrate their integrity as a regulator by acting fairly and not always supporting requests from NATS.

3. When NATS wishes to reorganise airspace routes, they hold a Consultation, which gives the impressionof being democratic. However, our experience is that NATS goes through the motions, but then ignores mostarguments against their case and is then supported by CAA approving the proposal from NATS.Complainants may spend large sums of money and much time in preparing a case against such proposalswhen they feel justified. If the result is inevitably against any objection to a proposal from NATS, then thismoney, time and eVort is wasted, which increases a feeling of cynicism against government. There is awidespread opinion, based on experience of a number of recent cases, that CAA and NATS are very arrogantin their handling of questions and objections. Often these questions are ignored and relevant information(needed to develop a balanced case) which is requested from NATS is denied. CAA do not appear to takethis into account when reaching their final decisions. CAA eVectively acts as judge and jury. CAA shoulddemand that NATS respond more fairly to requests for information and to any reasonable criticism theyreceive.

4. While accepting that endless appeals cost money and waste time, there should at least be a simpleappeal process following CAA’s decisions. This process should be accessible to concerned members of thepublic without involving them in unreasonable expense. At present, the only form of appeal is JudicialReview which can only be applied against alleged failure of process, not disagreement with decision. Inaddition, the expense of a Judicial Review can be prohibitive, eVectively denying members of the public theright of appeal. Where a complaint is based on environmental objections, we contend that the AarhusConvention applies and that the cost of any legal action must not be prohibitively expensive. We requestthat a simple legal appeal process be adopted that can be aVorded by normal people, without costing themor CAA unwarranted expense.

We request the Parliamentary Transport Committee to note the four points listed above and to implementthe reasonable actions requested.

October 2008

Memorandum from Virgin Atlantic Airways Ltd (AIR 12)

1. Virgin Atlantic is pleased to submit evidence to the House of Commons Transport Select CommitteeInquiry into the use of airspace. As the UK’s second largest airline, Virgin Atlantic is well placed to respondto the Committee’s request for views on this issue.

2. Virgin Atlantic’s answers to the questions asked by the Committee in its call for written evidence areset out below.

What changes to the management of airspace could be required as a result of the additional airport capacityoutlined in the 2003 White Paper? Are the White Paper’s projections for increased passenger demand stillaccurate? Are all the measures to provide for increased passenger demand likely to be implemented?

3. To deliver the additional capacity envisaged in the 2003 White Paper, a number of complex airspacereviews are likely to be required to guarantee the safe and eYcient management of UK airspace. To ensurethat the airspace changes necessary are delivered, a more streamlined airspace change process is required.Virgin Atlantic is concerned with the seemingly overly conservative approach to how airspace use is planned.

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We agree that the Directorate of Airspace Policy (DAP) should be careful and thorough but, in our view,decisions take too long to be made. We believe this primarily stems from a lack of resources to administerand produce requirements, for example with procedure design.

4. We are now entering a period when airspace is particularly heavily used and ever more congested,particularly in the South-East of England. Virgin Atlantic is of the view that the traditional way that theCAA’s Airspace Policy team has approached the regulation of airspace is simply too slow. It has takentypically four to five years to make any changes—this is too cumbersome and does not respond adequatelyto the demands of the market. The needs of DAP’s commercial stakeholders should be a priority. RouteeYciency, which has important cost implications for airlines, is often regarded by DAP as a bonus ratherthan a core part of the decision-making process. DAP should be allowed to adopt a more dynamic airspacechange process to ensure greater speed and simplification of airspace change processes. In particular, weacknowledge the importance of environmental issues and consultation for lower airspace.

5. Virgin Atlantic recognises that recent economic turmoil has potentially softened short run passengerdemand. However, Virgin Atlantic does not anticipate that these short run eVects will substantially alter thelong run forecast demand profile outlined in the 2003 White Paper and the White Paper progress report(2006).

6. Many airport infrastructure and airspace measures will be necessary to fulfil anticipated passengerdemand as set out in the 2003 White Paper. Necessary airspace measures should be implemented at theearliest opportunity to ensure that airspace management does not act as a barrier to increase capacity in linewith the projections of the 2003 White Paper. In addition, airspace changes should be undertaken to ensuresuYcient airspace capacity to deliver the diVerent variations in capacity expansion which may arise.Airspace improvements often have the additional bonus of having environmental benefits.

Can safety be maintained as airspace is increasingly utilised? Is there a suitable interface between military andcivilian arrangements for air traYc control?

7. For Virgin Atlantic safety is our highest priority in any decision regarding the utilisation, managementor changes in airspace, as it is with our own airline operation. Airspace utilisation can only be increased ifsafety margins are assured. However, increased airspace capacity can be delivered whilst maintaining safetythrough airspace change processes and investment in aircraft and ground technology. Airspace changes caninclude standardising routes and reduced complexity. For example, by using modern technology (eg P-RNAV) to optimise routeings, significant benefits in terms of safety and additional capacity could bedelivered.

8. The increased involvement of Europe through the Single European Skies (SES) initiative is addingcomplexity to what is already a complicated relationship between DAP, the military and commercial andgeneral aviation users of UK airspace. In Virgin Atlantic’s view, DAP on the whole appreciates theimportance of commercial air transport to the UK economy, but at times we believe that the historical pre-eminence of military requirements is still evident. The current air traYc control interface between militaryand civilian arrangements works well. Overall, DAP manages the tensions between the conflicting users well,but more could be done to improve route eYciencies. SES will, we hope, make a major contribution to this.Virgin Atlantic does not foresee that increases in capacity would undermine this interface.

Is the current approach to planning and regulating the use of UK airspace adequate? Would an Airspace MasterPlan covering the period of the White Paper be beneficial? Could a piecemeal approach to individualdevelopments necessitate additional redesigns subsequently?

9. Virgin Atlantic believes that the current approach to planning and regulating UK airspace is adequate.However, the processes followed by DAP in regulating UK airspace could be streamlined. We recognise theneed to consult and that consultation should take place with the appropriate parties. However, we believethat measures could be taken to reduce the burdensome nature of some DfT and DAP processes to increasethe speed of change and to ensure that regulatory oversight is appropriately targeted. Such measures wouldenable DAP to be more agile to react to altered capacity requirements.

10. Virgin Atlantic believes that an airspace masterplan would be an advantageous development. Such amasterplan would provide a helpful framework to ensure that all aspects of the 2003 White Paper aredelivered. However, it would need to be based on realistic assumptions of the likely delivery timescales andcommercial realities of the proposals suggested in the White Paper with regards to future airportinfrastructure and passenger demand. A piecemeal approach to airspace redesign may require futureredesigns or may lead to unnecessary complexity or ineYcient routeings being maintained.

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Transport Committee: Evidence Ev 125

How are the eVects of aircraft noise and emissions taken into account when changes are made to the use ofairspace? Who should be consulted about such changes? How should the balance between conflicting interestsbe struck?

11. Extensive consultation processes are undertaken when airspace changes are proposed. As a keycomponent, the eVects of aircraft noise and emissions are taken into account. Virgin Atlantic supports theprinciple that when assessing airspace redesign a number of environmental benefits should be optimisedwhilst ensuring safety and delivering operational requirements. In particular, we recognise the need tominimise noise impacts on local populations and reduce fuel burn (and therefore emissions).

12. All relevant stakeholders should be consulted or have the opportunity to comment on proposedairspace changes. In particular airspace users, airports and the general public, where they are aVected shouldbe consulted.

13. We recognise that it is necessary to make a judgement when balancing conflicting factors. In principle,Government Policy should guide this process. We were pleased to note that in the recent Terminal ControlNorth Consultation, NATS set out some broad criteria in order to balance conflicting interests. NATSproposed the redesign of the TCN area by prioritising flights on routes:

— below 4,000 feet to avoid large populations;

— between 4,000-7,000 feet to where possible mitigate noise impact whilst also reducing fuel burn andemissions; and

— above 7,000 feet to increase fuel eYciency and reduce emissions.

14. By setting out broad principles, NATS was able to propose an airspace redesign which balancedsafety, capacity, growth and operational requirements, whilst also having regard for environmental factors.

15. Virgin Atlantic is concerned that not enough attention is given by DAP to Environmental ImpactAssessments and Regulatory Impact Assessments before decisions are taken. Nowadays these should be abasic input to any significant regulatory action.

How does the management of airspace in the rest of Europe aVect flights into the UK? Is there an opportunityto integrate our plans for changes to airspace management more eVectively with those of other Europeancountries?

16. Airspace across Europe is fragmented between a large number of airspace sectors. Aircraft passingthrough each sector are managed by the associated air traYc control agency before responsibility is passedonto the next agency. Due to the fragmented nature of airspace management, this potentially leads to sub-optimal flows into the UK.

17. Developments within the Single European Sky (SES) programme and the development of FunctionalAirspace Blocks (FABs) are intended to reduce the complexity of European airspace management andconsolidate appropriate airspace sectors. These developments will create airspace managementimprovements, for example, the exploration of a UK/Eire FAB will increase the eYciency of airspacemanagement, ensure better flows of air traYc into and through UK airspace and provide better, moreeYcient routeings.

18. A UK airspace masterplan, and any subsequent proposals to change UK airspace, will need to haveregard to and fit within the developments proposed as part of the SES and the evolution of FABs in Europe.

What opportunities are there to apply new techniques and technologies to reduce wasteful flying on indirectroutes and excessive “stacking” while planes wait to land? How can the potential of any such opportunities bestbe realised? Could environmental benefits be gained as a result of such improvements?

19. A significant proportion of modern aircraft are able to operate in more automated and advancedairspace. However, the use of advanced technology onboard has been constrained by the lack of investmentin associated ground infrastructure. SES will allow for the development and use of new techniques andtechnologies to improve eYciency, particularly with regard to delivering advanced ground infrastructure.

20. By consolidating complimentary airspace sectors, FABs seek to create more eYcient, direct routeingsthrough complex airspace sectors, reducing wasteful flying.

21. Utilising existing runways more eYciently (eg through mixed mode) and adding new runways willcreate opportunities to reduce unnecessary holding in stacks and ground delays. Ensuring investment intechnology and a commitment by EU governments is necessary to ensure that such opportunities arerealised.

22. Technology enhancements, improved techniques, simplified airspace with more direct routeingsalongside reduced ground and airborne holding will all lead to significant environmental improvements.

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In relation to the redesign of UK airspace, is the allocation of the roles and responsibilities of each of theinterested parties-Department for Transport, the CAA, airport operators, NATS, etc-appropriate and clearlyunderstood? Are the structures of the parties appropriate for undertaking the roles that they should play?

23. Virgin Atlantic is satisfied that the allocation of roles between interested parties is adequate. However,we are not convinced that the various roles or responsibilities are clear or understood by all stakeholders,particularly in relation to ongoing airspace management developments.

24. Roles and responsibilities between stakeholders have been allowed to develop organically in responseto ongoing airspace changes. This has in some instances led to a degree of fragmentation between interestedparties and in some areas roles and responsibilities with regard to airspace redesign have not kept up withthe pace or type of airspace changes.

25. It is Virgin Atlantic’s opinion that given the significant changes that European airspace managementwill undergo, as a result of SES and the development of FABs, it may be healthy to review the structure,roles and responsibilities of stakeholders to check that these are consistent and eVective to deliver necessaryairspace change.

Do airspace management considerations delay the planning processes in relation to airport developmentproposals? How will airspace management considerations be taken into account by the proposed newInfrastructure Planning Commission and the relevant National Policy Statements on airport planning?

26. Airports that take forward airport development proposals are better placed than Virgin Atlantic tojudge how far airspace management considerations delay the planning processes in relation to the proposals.

What could be the implications for smaller airfields, recreational flying and helicopters of changes to airspacemanagement to enable safe and eYcient increases in capacity at the UK’s major airports? How should anappropriate balance between conflicting priorities be determined?

27. Consultation processes on airspace change and management take into consideration the requirementsof all users of the airspace. All airspace users as interested parties are invited to respond to airspaceconsultations. The consultation process would seek to manage and optimise competing airspace demands.Strategic decisions on the use of airspace should flow from national Government policy.

Will it be possible to recruit and train staV in order that airspace changes can be implemented in parallel withadditional airport capacity?

28. Virgin Atlantic does not envisage that airport capacity and airspace change developments will behindered by recruitment or training issues. NATS would be commercially incentivised to managerecruitment and training programmes to ensure that airspace changes are implemented.

Who should fund airspace changes? Is there likely to be enough funding to undertake the redesign required tobring about the necessary additional airspace capacity?

29. Strategic airspace changes should be funded by government, airports and the suppliers of air traYcmanagement services. Government should fund airspace change processes to ensure that wider objectivesof national policy are delivered, eg benefits to the wider economy and environmental criteria. Although thelevel of funding required to deliver additional airspace capacity is uncertain, Virgin Atlantic does notenvisage any issues in respect of the availability of funding, as air traYc management providers will becommercially incentivised to undertake airspace redesign to increase airspace capacity.

October 2008

Memorandum from Save Our Peace and Quiet (SOPAQ) (AIR 13)

— This submission has been prepared by the campaign group SOPAQ which was set up in WestSuVolk in response to the NATS proposals to site an aircraft stacking hold over West SuVolk.

— SOPAQ, along with many other residents from the area, campaigned vigorously to make peopleaware of the proposals and their potential impact on residents from increased aircraft noise andaircraft emissions.

— SOPAQ is particularly concerned about expansion of airports and the eVects on the environmentin terms of noise and air pollution and would like to submit its response to the following questions:

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1. How are the eVects of aircraft noise and emissions taken into account when changes are made to the use ofairspace? Who should be consulted about such changes? How should the balance between conflicting interestsbe struck?

NATS consulted residents about their views on the potential impact of its proposals. According to theNATS feedback report issued in July 2008 578 responses were received by representative groups such asparish, district and county councils who represent a large number of residents. 14,647 members of the publicalso responded individually. Of those who responded 86% were opposed to the proposals. The main reasonfor opposition was concern about noise in rural areas where tranquillity is valued. SOPAQ believes thatresidents who will be aVected by changes to the use of airspace should be consulted as widely as possiblebut is concerned that any consultation is of little value should the findings be ignored. NATS has recentlyannounced that it is still evaluating the feedback it has received.

The initial feedback report from NATS acknowledged concerns about noise and tranquillity but as yetno information has been released as to whether these concerns will be reflected in any changes to the originaldesign of the holds or indeed whether the need for holding will be reconsidered in the light of such strongopposition. Whilst SOPAQ accepts that it is diYcult to strike a balance between conflicting interests, itbelieves that the positioning of aircraft holds over tranquil rural areas will have a damaging impact on theenvironment and quality of life. Whilst the rationale of minimising the number of people aVected by aircraftnoise is understood, the ambient noise levels in rural areas are considerably less than in built up areas andany increase in noise is noticeable. If the proposals go ahead some of the most beautiful and tranquil areasin the East of England will be lost forever. InsuYcient consideration has been given to the importance ofthese areas of “calm” both for local residents and visitors from towns and cities. The United Kingdom isalready facing huge pressure to build more housing and for urban development. It is vital to preserve thecountryside for people to enjoy in the future.

SOPAQ is also concerned about the aVect on health of the noise pollution which will result from the NATSproposals. The World Health Organisation has carried out research which suggests that 3% of heart attackdeaths can be attributed to stress induced by noise pollution.12 For residents living in areas which at presenthave virtually no ambient noise, the potential impact on wellbeing and health should be taken intoconsideration. With the noise of a typical aircraft flying at 4000ft (the lowest height limit given by NATSfor the Stansted Western arrivals hold) being given as 69dB, equivalent to a car driving 40 miles per hour23 feet away, the level of disturbance will be way in excess of noise experienced in quiet rural areas.

Very little information was given in the initial consultation document about the possible aVects on airquality. An increase in aircraft flying over rural areas must be detrimental air quality.

SOPAQ believes that we should all be questioning whether the continuing expansion of air travel issustainable. With growing concerns about climate change and the very real dangers to our world as we knowit, there is now clear evidence that air travel is the fastest growing source of green house gases. Accordingto the Friends of the Earth report Aviation and Global Climate Change’ aviation is the fastest growingsource of carbon dioxide in the UK. Carbon Emissions from UK aviation increased by 11% in 2004 alone13

and are estimated to increase four fold between 2000 and 2050.14

Friends of the Earth has recently launched its Big Ask campaign calling for the government to includeaviation emissions in its Climate Change bill. If aviation emissions are excluded, and indeed if aviation isallowed to continue to expand, the potential impact on the environment will be huge. Aviation emissionshave between two and four times the impact of carbon emissions alone due to complex chemical reactionsat altitude.15 Any improvements in managing the reduction of aviation emissions will be countered by thecurrent growth in passengers of 6.4% per year.16 The Environmental Change Institute at Oxford Universityrecently concluded that it will be impossible to meet the UK’s 60% carbon reduction 2050 climate targetwithout curbing aviation growth.17 Allowing unrestricted airport expansion is contrary to the UK’s statedintention of tackling climate change. Once airport expansion goes ahead it will be impossible to reverse theeVects of aviation emissions on climate change as passenger numbers increase. As a nation we should belooking at ways to reduce our dependency on air travel and find alternative greener methods such as railtravel, particularly within UK and Western Europe.

2. What changes to the management of airspace could be required as a result of the additional airport capacityoutlined in the 2003 White Paper? Are the White Paper’s projections for increased passenger demand stillaccurate? Are all the measures to provide for increased passenger demand likely to be implemented?

SOPAQ believes that we should all be questioning whether expansion of air travel is realistic in view ofthe current problems being faced by the aviation industry. Since the NATS proposals were introduced, therehas been a massive increase in the cost of oil and a number of airlines have already been forced to reducetheir services and others have collapsed. As the “credit crunch” begins to aVect more and more people, flying

12 Quantifying the burden of disease from environmental noisew second technical meeting report—World Health Organisation.13 DEFRA figures including international flights.14 Predict and decide: aviation, climate change and UK policy p 14.15 Predict and decide: aviation, climate change and UK policy pp 16–17.16 Eurostat figures p 49 Growth Scenarios.17 Predict and decide: aviation, climate change and UK policy.

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Ev 128 Transport Committee: Evidence

will become a luxury that fewer people can aVord. Although the government has predicted an increase inthe number of passengers passing through UK airports, is this now likely? Do government figures includethe number of people transiting through UK airports en route to other destinations? Over the past yearfigures for Stansted airport show a reduction in passenger numbers, not an increase, thus calling to questionwhether the predictions are accurate and whether expansion is necessary. In August 2008, the number ofpassenger movements through Stansted decreased by 4.7% and air transport movements (passenger andcargo) were down by 8%.18 These figures reflect a continuing downward trend which began in October 2007calling into question predictions of an increase in passenger demand.

As people become more aware of the environmental impact of air travel SOPAQ believes that people willtry to find ways to reduce the number of flights they take and find alternative methods of travel.

3. What opportunities are there to apply new techniques and technologies to reduce wasteful flying on indirectroutes and excessive “stacking” while planes wait to land? How can the potential of any such opportunities bestbe realised? Could environmental benefits be gained as a result of such improvements?

SOPAQ believes that holding is not an eYcient method of managing flights in terms of increased fuelconsumption, as aircraft divert from direct flight paths into the holds and during holding, as well as theenvironmental impact of aircraft holding on air quality and noise levels.

October 2008

Memorandum from Natural England (AIR 14)

Summary

1. Natural England is concerned by the potential landscape and biodiversity impacts of airport expansionand the airspace changes required to accommodate this expansion.

2. The lack of a methodology to assess the impacts of increased overflying at diVerent altitudes on thetranquillity of protected landscapes and open countryside means that the impacts and their significancecannot be clearly established.

3. We support the proposal for an Airspace Masterplan and recommend that a Strategic EnvironmentalAssessment of this plan is carried out which will help to establish the direct, indirect and cumulativeenvironmental impacts of airspace change.

Evidence

4. Natural England has been charged with the responsibility to ensure that England’s unique naturalenvironment including its flora and fauna, land and seascapes, geology and soils are protected and improved.Natural England’s purpose is to ensure that the natural environment is conserved, enhanced, and managedfor the benefit of present and future generations, thereby contributing to sustainable development.

5. Our evidence relates to two of the inquiry questions in particular:

(i) Is the current approach to planning and regulating the use of UK airspace adequate? Would anAirspace Master Plan covering the period of the White Paper be beneficial?

(ii) How are the eVects and aircraft noise and emissions taken into account when changes are madeto the use of airspace? Who should be consulted about such changes? How should the balancebetween conflicting interests be struck?

6. Current Government policy supports a doubling of air passenger flights by 2030 with significantexpansion at Heathrow and Stansted. With the recent Competition Commission conclusion that BAA’sownership of seven UK airports is counter-competitive, expansion at Gatwick may also be brought forward.Whilst the statutory processes for this expansion have yet to proceed, the policy context provides strongsupport for expansion focused in the south east of England. In addition, many regional airports arevigorously pursuing expansion plans in accordance with the Air Transport White paper. It is therefore likelythat a significant amount of expansion will proceed, although there are many variables that may aVect thissuch as the forthcoming Climate Change Bill, the economic climate and fuel prices.

7. Natural England is concerned by the potential landscape and biodiversity impacts of airport expansionand the airspace changes required to accommodate this expansion. We have recently objected to theexpansion plans for Stansted, London Ashford and Bournemouth Airports due to potential impacts onnationally and internationally protected sites and species caused by the proposals. Further expansion at

18 www.baa.com—Stansted Passenger and ATM statistics.

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Heathrow will damage local landscape character and adversely aVect local biodiversity. If they proceed,these expansion plans are likely to lead to a further increase in overflying of protected landscapes andenvironmentally sensitive sites.

8. Recent airspace changes by NATS (National Air TraYc Control Services) to accommodate growingnumbers of flights are already leading to increased overflying of the New Forest National Park, the NorthWessex Downs, the Cotswolds, the Mendips, the Quantock Hills, the Blackdown Hills, the Shropshire Hillsand the East Devon Areas of Outstanding Natural Beauty (AONBs). If the proposals set out in the recentNATS consultation on the TCN (Terminal Control North) airspace are accepted, they will also lead toincreased overflying of the Chilterns AONB at less than 7,000 feet in order to reduce overflying of Wendoverand Princes Risborough from Luton departure flights. Some protected landscapes are benefiting from areduction in overflying as a result of these recent changes—for example, the Dedham Vale AONB shouldexperience a decrease if the TCN proposals are implemented. Overall, the level of overflying of protectedlandscapes is increasing.

9. It is worth noting the legislation backing the protection of these landscapes. National Parks (NPs) &Areas of Outstanding Natural Beauty (AONBs) have been confirmed by the Government as having thehighest status of protection in relation to landscape and scenic beauty. Each of these designated areas hasspecific statutory purposes which help to ensure their continued protection. National Park purposes are toconserve and enhance their natural beauty, wildlife and cultural heritage and to promote opportunities forthe understanding and enjoyment of their special qualities by the public. The statutory purpose of AONBsis to conserve and enhance the natural beauty of their area. In both instances this includes the concept oftranquillity.

10. Each of the Acts relating to these areas places a general statutory duty on all relevant authorities &bodies, requiring them to have regard to their purposes as set out above. The statutory duties are providedfor in Section 11A (2) of the National Parks and Access to the Countryside Act 1949 (National Parks) &Section 85 of the Countryside and Rights of Way Act (CROW) 2000 (AONBs). For National Park andAONB duties the Civil Aviation Authority (under s.19 of, and Schedule 2 to the Civil Aviation Act 1982),is regarded as a statutory undertaker.

11. We recognise that airspace changes are largely a technical response to changes on the ground, and thatif national policy supports airport expansion, NATS will be required to accommodate the resulting increasein flights in the safest possible way. The trend towards increased overflying of protected landscapes and opencountryside is at least in part due to the Department for Transport’s guidance to the Civil AviationAuthority, which supports the avoidance of overflying environmentally sensitive areas only where it iseconomical and safe to do so, and where it will not result in more heavily populated areas suVering greaterdisturbance.19

12. This means that it will be England’s less populated areas that absorb the impacts of continuingchanges to airspace. Natural England is concerned that the ongoing expansion of airports, flights andairspace will impact negatively on biodiversity, landscape and recreation, causing visual intrusion, loss oftranquillity, and increases in noise and air pollution.

13. It is important and in keeping with other aspects of Government policy to protect these designatedareas from negative impacts. The EU Directive on Environmental Noise 2002 states that member statesshould maintain environmental noise quality where it is currently good. The Government’s rural policiesstate that “protecting the countryside from further intrusion of noise is not a luxury”20 and identifytranquillity as one of the key elements that we value about the countryside, with the tranquillity andattractiveness of the countryside oVering “a major opportunity for rural businesses in the recreation andtourism sector”.21 Tranquillity is often used in Landscape Character Assessments (LCAs) to describe thespecial quality of a landscape. The Campaign to Protect Rural England’s (CPRE) research into tranquillityhas shown that the presence of aircraft undermines tranquillity by bringing man-made noise and visualintrusion into a “natural environment”.22

14. Noise is measured by its impacts on the population and so sparsely populated areas are not deemedto be greatly aVected. Natural England is concerned by this on two points:

— Aircraft noise remains out of place in the countryside and is an intrusion that impacts on people’senjoyment of the countryside. Even if decibel levels remain under the threshold for communityannoyance, there is the key issue of low level aircraft noise becoming more frequent due to shortergaps between each flight.

— As air travel growth continues, the pressures to overfly and move stacks to less populated areas inorder to ease the impacts on populated areas will increase. It is not clear how the countryside anddesignated landscapes will be protected from this.

19 Guidance to the Civil Aviation Authority on Environmental Objectives relating to the exercise of its air navigation functions(Department for Transport, 2002).

20 Rural White paper, 2000 Defra page 111, Section 9.4.21 Rural Strategy, 2004 Defra page 34.22 CPRE Tranquillity mapping, 2006 http://www.cpre.org.uk/campaigns/landscape/tranquillity/our-tranquillity-map-

explained.

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15. We have responded to a number of recent airspace change and air traYc control consultationsexpressing these concerns. Airspace consultations do consider the impact of their proposals on tranquillityand generally recognise that tranquillity, despite its subjective nature, is a decreasing and highly valuedresource that should be protected. However, whilst the resulting decisions have acknowledged tranquillityas an issue and also our concerns about its loss, they have always proceeded with the original proposalsunchanged. The lack of a methodology to assess the impacts of increased overflying at diVerent altitudes onthe tranquillity of protected landscapes and open countryside means that the impacts and their significancecannot be clearly established.

16. Regarding the TSC’s question of an Airspace Masterplan (AMP), we have previously urged NATSto raise the long term implications of changes to airspace for designated landscapes and the widercountryside with the CAA and DfT, and have called for an assessment of the cumulative eVects that willbe caused by airspace changes to accommodate the Air Transport White Paper’s expansion plans. We haverecommended that additional work is undertaken into the eVects that growth in air travel is likely to haveon the demand for expanded air space over designated landscapes and other high quality rural landscapes,beyond 2018. We therefore support the TSC’s suggestion of an Airspace Masterplan.

17. However, airport masterplans, which set out individual airport’s expansion plans over a set timescale,have no statutory status and do not require any type of environmental assessment—Strategic EnvironmentalAssessment (SEA) being the most appropriate. We recommend that the AMP should be subject to an SEA,whether or not it has statutory status. This should be seen as good practice and in keeping with the sprit ofexisting CAA guidance that seeks to assess the environmental implications of changes to airspace.

October 2008

Joint memorandum from the Air Safety Group (ASG) and the Parliamentary Advisory Council forTransport Safety (PACTS) (AIR 15)

Summary

This response to the House of Commons inquiry comes from both the Air Safety Group and theParliamentary Advisory Council for Transport Safety and concentrates on the safety issues.

The main concerns in the response relate to the following areas:

— concerns over the increasing complexity of the air traYc controller task;

— safety in uncontrolled airspace;

— the mandatory carriage of Mode S Transponders and TCAS;

— just Culture and Incident reporting;

— civil/military incidents;

— the safety of Unmanned Aerial Vehicles and Very Light Jets;

— the lack of capacity in the South East of the UK and its impact on runway utilisation, resilience,aircraft stacking, inter-arrival times and safety margins; and

— consultation and decision making regarding airspace design and airport development and theresulting delay in addressing capacity constraints, and therefore safety concerns.

Response to Questions Posed by the Inquiry

[Note that Questions from the Inquiry are shown in Italics]

Q1. What changes to the management of airspace could be required as a result of the additional airportcapacity outlined in the 2003 White Paper? Are the White Paper’s projections for increased passenger demandstill accurate? Are all the measures to provide for increased passenger demand likely to be implemented?

1.1 The White Paper forecasts have been relatively accurate in terms of predicting overall passengergrowth but there has been substantial change since 2001 in the traYc distribution across the UK arising fromimpacts of 9/11 and the growth in the low cost carriers. These distribution eVects would not have been takeninto account in the 2000 forecasts on which the conclusions of the White Paper were made.

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Q2. Can safety be maintained as airspace is increasingly utilised? Is there a suitable interface between militaryand civilian arrangements for air traYc control?

Increased Complexity

2.1 The main concerns here relate to the increasing complexity of the controller task, and the increasingreliance on safety net systems (eg STCA and TCAS), which were originally designed as an extra layer, buthave now become embedded as part of the whole risk management strategy.

2.2 Regarding complexity, our concern is that as the controller task becomes more complex and he/shehas to increasingly rely on computer tools (such as FACTS, being developed by NATS), so the ability torevert to manual mode becomes more problematic. Whilst ATC systems have become more reliable over theyears, they are not immune from failure, as evidenced by the recent computer problems at Swanwick on 25thSeptember. Once the system becomes so complex such that the air traYc controller can no longer hold thepicture in his head, the impacts of a computer failure become much more problematic. It is akin, whendriving, to placing too much reliance on a satellite navigation system, without actually following where oneis. For example, there are many recorded incidents of drivers blindly following their sat-navs and turningonto railway lines.

2.3 Regarding safety net systems, the risk classification of an Airprox is largely determined by the closestpoint of approach of the two aircraft concerned. If two aircraft are inadvertently on conflicting paths, butminimum separation is never eroded, due to activation of a safety net (eg through the pilot’s response to hisTCAS or to instructions from ATC), the risk of collision will be deemed low. But this risk classificationapplies to that incident only—the fact remains that the causal events of the incident happened and couldhappen again when no safety nets are present. We believe it is important that these underlying trends aremonitored in order that the true risk of increasing airspace complexity can be estimated. Another goodexample would be level busts, where an aircraft climbs or descends to the wrong flight level. If there isanother aircraft in the vicinity at the same flight level, it might result in an Airprox, but if there happens tobe no other aircraft present, it is deemed of no risk. In both cases, an error has occurred but in the secondcase it was just fortuitous that no other aircraft was present.

Safety in Uncontrolled Airspace

2.4 We strongly support the Airspace & Safety Initiative (ASI) set up jointly by the CAA, NATS, theAirport Operator’s Association, General Aviation and Ministry of Defence. We also support thedevelopments regarding Air TraYc Services Outside Controlled Airspace (ATSOCAS). Uncontrolledairspace is being increasingly used by commercial flights from regional airports and it is critical that similarlevels of safety can be assured compared to controlled airspace.

2.5 We believe the priorities for the ASI and ATSOCAS are to find feasible solutions that will allow theextension of the mandatory carriage of Mode S Transponders and TCAS to as many aircraft types andairspace users as possible. Carriage of a Mode S Transponder is critical for the detection of airspaceinfringements (a current concern to NATS, CAA SRG and Eurocontrol SRC), and for the detection bySTCA and TCAS safety net systems. Carriage of transponders would also help alleviate radar returninterference concerns from the development of Wind Farms.

Civil/Military Issues

2.6 In terms of civil/military ATM co-operation, we believe that the UK model is one of best practicewithin Europe, but this is an assertion without proof. There are incidents where military aircraft infringecontrolled airspace or incidents arising from the Flexible Use of Airspace where civil aircraft infringe dangerareas. We believe these incidents, along with all civil/military Airproxes should be separately monitored andtrends established. Whilst the Airprox Board and MOD do an excellent job of investigating individualincidents, it is equally important that the trends in the underlying causes are identified and shared.

Incident Reporting

2.7 It is very important that the “just culture” for reporting of incidents is maintained. The UK againleads by example, but there are many countries in Europe where incident reporting falls short of evenminimum requirements. The UK needs to continue to support the Eurocontrol and ICAO initiatives on thisand use its influence to ensure that just culture becomes enshrined in European Law.

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Unmanned Aerial Vehicles (UAVs)

2.8 We are aware of a number of initiatives on this important subject in the UK and Europe, includingwithin Eurocontrol, NATO and the European Defence Agency. We are not aware however of how “joinedup” these initiatives are. The use of UAVs is growing and represents a potential safety hazard for the future.We believe that the results from these initiatives should be shared so that the potential failure modes of UAVoperations can be understood. Airworthiness, Operations and ATM regulations need to be developed at theEuropean level through EASA.

Very Light Jets (VLJs)

2.9 There are similar concerns over the safety of Very Light Jets and the impact these will have on thecomplexity of the controller task.

Q3. Is the current approach to planning and regulating the use of UK airspace adequate? Would an AirspaceMaster Plan covering the period of the White Paper be beneficial? Could a piecemeal approach to individualdevelopments necessitate additional redesigns subsequently?

3.1 This would be a good idea but unfortunately is not feasible. Until firm airport development decisionsare made for the South East of England, it would be impossible to produce an airspace management plan.For example, the impact of a second runway at Stansted and/or a third runway at Heathrow would be sosubstantial that a whole new airspace pattern over a significant part of the UK would be necessary.

Q4. How are the eVects and aircraft noise and emissions taken into account when changes are made to the useof airspace? Who should be consulted about such changes? How should the balance between conflicting interestsbe struck?

4.1 Safety is also an issue here. Whilst environmental concerns are legitimate, safety considerationsshould be paramount. The airspace planning consultation process (CAP725) is becoming ever moreprotracted. It is increasingly diYcult to develop routes that satisfy conflicting environmental needs to avoidboth tranquil and built-up areas. The need for route development, coupled with the provision of additionalairspace capacity, arises in response to increasing complexity and congestion. The latter can quickly becomesafety issues, if the provision of additional capacity is delayed due to the protracted consultation process.

Q5. How does the management of airspace in the rest of Europe aVect flights into the UK? Is there anopportunity to integrate our plans for changes to airspace management more eVectively with those of otherEuropean countries?

5.1 No safety-related comments to make on this issue.

Q6. What opportunities are there to apply new techniques and technologies to reduce wasteful flying on indirectroutes and excessive “stacking” while planes wait to land? How can the potential of any such opportunities bestbe realised? Could environmental benefits be gained as a result of such improvements?

6.1 Stacking is a safety issue as well as an environmental one. In terms of runway utilisation, Heathrowand Gatwick are the most eYcient dual and single runway airports in the world, but this comes at a cost ofcongestion, delay and reduced resilience to unplanned events such as strikes, adverse weather and terroristincidents. Stacking is necessary to ensure that queues are maintained and that the runways remain fullyutilised, but this level of utilisation also means that inter-arrival times are reduced to a minimum, therebyeroding the safety margin for error.

6.2 The congestion and stacking issue can be tackled in one of two ways, either through changes in airtraYc management (ATM) or by increasing the available runway capacity.

6.3 The increasingly protracted planning enquiries to provide additional runway capacity in the SouthEast mean that the current congestion at the London airports has become the “accepted norm”, rather thanthe “imperative to address” that it should be. If there was a mid-air collision due to airspace congestion inthe South East, it would more likely result in a call to impose reduced runway utilisation rates (ie treatingthe symptom) rather than providing the impetus to build new runways (ie addressing the cause). But thiswould be the wrong response, since if new runways were provided, part of this additional capacity could beused to improve resilience and safety margins by reducing the need for stacking. It would be important tosafeguard this element of the additional capacity against the commercial pressures to increase utilisationrates to cover the pent-up demand.

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6.4 In terms of ATM, NATS needs to press ahead with the development of their Future Area ControlTools Support (FACTS) system. In addition, the Government needs to continue to provide support to thedevelopment of the European Single European Sky and the implementation of the ATM Master Plandeveloped under SESAR. These long term initiatives are all aimed at developing new concepts of operationthat will impact on “gate to gate planning” with just in time arrivals that will reduce the need for stacking.

Q7. In relation to the redesign of UK airspace, is the allocation of the roles and responsibilities of each of theinterested parties-Department for Transport, the CAA, airport operators, NATS, etc-appropriate and clearlyunderstood? Are the structures of the parties appropriate for undertaking the roles that they should play?

7.1 Yes, it is important that, as part of the CAA, the Directorate of Airspace Policy oversees the processto ensure an equitable treatment of all airspace users.

Q8. Do airspace management considerations delay the planning processes in relation to airport developmentproposals? How will airspace management considerations be taken into account by the proposed newInfrastructure Planning Commission and the relevant National Policy Statements on airport planning?

8.1 The following principles should be adopted. Decisions on airport development need to be made first.This provides the certainty of the airspace management task. Whilst ATM feasibility issues need to beconsidered when making decisions regarding airport development, more detailed ATM design should becompleted while the additional airport capacity is being built. Trying to do detailed design at the decisionphase would be costly and potentially a waste of time. It would add to the procrastination over decisions,further lengthening the status quo over capacity while demand increases, leading to further congestion andthe reduction of safety margins.

Q9. What could be the implications for smaller airfields, recreational flying and helicopters of changes toairspace management to enable safe and eYcient increases in capacity at the UK’s major airports? How shouldan appropriate balance between conflicting priorities be determined?

9.1 Bicycles, cars and buses all adopt the same rules of the road, and airspace users should do the samein terms of airspace. While cost and feasibility issues of safety equipage are important considerations forrecreational flying, the safety issues should be paramount. The consequences of a mid-air collision betweena B737 and a Cessna 400 are fatal to both parties.

Q10. Will it be possible to recruit and train staV in order that airspace changes can be implemented in parallelwith additional airport capacity?

10.1 Yes, see response to Q8.

Q11. Who should fund airspace changes? Is there likely to be enough funding to undertake the redesign requiredto bring about the necessary additional airspace capacity?

11.1 As long as airspace changes are done equitably, all airspace users should contribute to the costs ofthe changes. This should be achieved through the airspace user charge.

11.2 Airspace change provides benefits to all users in terms of reducing complexity and routeineYciencies, and in increasing safety. But it is recognised that not all airspace users will receive the samebenefits from airspace change, and for some, the costs associated with additional equipage required may beproportionally larger. In this respect, the weight factor in the airspace user charge should be maintained inorder to reflect both the ability to pay and the cost/benefit ratio of the change to each user.

October 2008

Memorandum from the Guild of Air TraYc Control OYcers (GATCO) (AIR 16)

1. Executive Summary

The bullet points below provide a high level summary of the GATCO input to the inquiry by the Houseof Commons Transport Committee into the use of airspace.

— GATCO believes that the 2003 White Paper and associated Airport Master plans will requiresignificant development of UK airspace in the near future. Such development will need appropriatelevels of funding and resource in order to be progressed in a timely and eVective manner.

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— The economic downturn is likely to result in an interim decrease in Air TraYc Movements. Thiswill have the eVect of delaying growth in demand by a couple of years, in the opinion of the Guild.

— Safety is paramount in the provision of Air TraYc Control and the handling of aircraft in UKairspace. GATCO believes that adherence to well established Safety Management Systems,monitored by an independent safety regulator, is key to ensure that the excellent safetyperformance in the UK is maintained as airspace is further developed.

— Safety, eYciency, capacity and improved environmental performance are now the key driversbehind airspace change. In the past, the main driver has been capacity with resectorisations beingthe principal way of achieving improvements. The focus is now on improving the eYciency ofexisting sectors.

— GATCO believes that an airspace master plan, developed and maintained by those responsible formanaging the airspace, namely the Air TraYc Service Providers in general and NATS in particular,would enable a cohesive approach to future airspace development.

— The Guild recognises the rise in profile of environmental performance, including noise, emissionsand visual pollution. However, the guidance for taking environmental factors into account whendeveloping airspace is subject to frequent change and is lacking in prescriptive content. Clearpolicy on this subject is needed.

— GATCO is concerned that the airspace change process is unduly complex, requiring significantamounts of time, investment and resource. It is believed that the complexity and sheer size of theprocess may deter some smaller Air TraYc Service Providers from instigating airspace change. Thismay mean that potential safety benefits are not being realised.

— The Guild sees the role of new technologies and concepts, such as Arrival Management (AMAN)systems, Performance Based Navigation, Continuous Descent Approach and Controlled Time ofArrival, as being key to progressing improvements to the management of UK airspace in thefuture.

2. Introduction and Scope

The Guild of Air TraYc Control OYcers welcomes the opportunity to provide input regarding the use andmanagement of airspace. This paper constitutes the GATCO response to the House of Commons TransportCommittee’s inquiry into the use of airspace.

3. Discussion

3.1 Question 1

What changes to the management of airspace could be required as a result of the additional airport capacityoutlined in the 2003 White Paper? Are the White Paper’s projections for increased passenger demand stillaccurate? Are all the measures to provide for increased passenger demand likely to be implemented?

The demand portrayed in the 2003 White Paper is determined by forecast growth and by the intentionsoutlined in various airport master plans. These master plans are normally progressed in isolation fromsurrounding airspace and tend not to take airspace constraints or issues into account.

The recent downturn in the economy is having an impact on the demand for air travel. Some operatorshave also ceased trading as a result of financial diYculties. This has resulted in the number of Air TraYcMovements starting to decline. GATCO believes that the impact on airspace demand has eVectively beenput back by two years. However, the content of the airport master plans makes it clear that significantdevelopment of UK airspace will be required to support such plans.

3.2 Question 2

Can safety be maintained as airspace is increasingly utilised? Is there a suitable interface between military andcivilian arrangements for air traYc control?

GATCO’s view is that safety must be maintained as airspace is increasingly utilised. It is alwaysparamount to ensure the safety of aircraft and the people that they carry. The safety culture and systemsused in the management of the UK airspace are probably the best in the world. The continued applicationof the Safety Management Systems (SMS) used by the Air TraYc Service Providers in the UK, together withthe regulation of these SMS by the CAA’s Safety Regulation Group should ensure that safety is maintained.

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Transport Committee: Evidence Ev 135

As safety must be ensure, the use of airspace must be regulated on both a tactical and a strategic basis toensure that the amount of traYc utilising the airspace is not allowed to get to levels that cannot be safelyhandled by the Air TraYc Control system. The Air TraYc Service Providers, especially NATS in the en-routeenvironment, together with the regulatory authority, Director Airspace Policy, are fundamental inachieving this.

The interface between military and civilian Air TraYc Control is generally of a good standard in the UK.Some of the area functions are conducted from a single, integrated operations room, namely the AreaControl Room at the Swanwick centre. Arrangements, such as Airspace Management Cell, ensure that theuse of joint airspace is coordinated between civil and military ATC. Flexible Use of Airspace is alreadypracticed in the UK, ensuring that airspace is shared in an eYcient manner between military and civil users.

3.3 Question 3

Is the current approach to planning and regulating the use of UK airspace adequate? Would an Airspace MasterPlan covering the period of the White Paper be beneficial? Could a piecemeal approach to individualdevelopments necessitate additional redesigns subsequently?

GATCO believes that the planning of UK airspace has been undertaken in the past in response toincreasing demand. The planning of airspace developments has previously been focused on providingadditional capacity and resectorisation, ie the division of a given volume of airspace into multiple sectors,has been a key means of achieving this. However, the benefits of resectorisation are now reducing due todiminishing returns as there is a finite amount of additional capacity to be had from splitting into moresectors. The way forward for capacity gains is through improved eYciency of the finite airspace in the UK.

The historical focus on the provision of additional capacity is now changing as new factors need to betaken into account. Safety continues to be paramount in any airspace development. An increased interest inenvironmental issues means that consideration to environmental factors, such as noise, emissions and visualpollution, is now a core component of airspace development. Planning airspace today consider changes asa three legged stool, with the legs being safety, capacity and the environment.

The Guild believes that an airspace master plan for airspace developments is required for the future, ratherthan the piecemeal approach that has been adopted in the past. However, the owners of this master planshould be those who have the expertise to produce such a plan and the capability to implement the changesthat it calls for. GATCO suggests that such a master plan should be in the remit of the Air TraYc ServiceProviders, and that NATS, as the largest ATSP is probably best placed to develop and own such a strategy.

Any proposed airspace master plan should be progressed in conjunction with the latest informationavailable as to the intentions of airport development.

3.4 Question 4

How are the eVects and aircraft noise and emissions taken into account when changes are made to the use ofairspace? Who should be consulted about such changes? How should the balance between conflicting interestsbe struck?

Environmental factors, including aircraft noise and emissions, have rapidly risen up the list ofconsiderations when designing airspace. Draft guidance is available from the Civil Aviation Authority forenvironmental considerations. However, the guidance is still “woolly” and provides little in the way of actualhard and fast criteria that could be adhered to and subsequently measured against. GATCO believes thatguidance for environmental considerations should be developed further so it is no longer “draft” butbecomes actual policy, containing published criteria that can be taken into account when developingairspace and that can subsequently be used to measure environmental performance against.

GATCO feels that the draft guidance that is available is overly protective of the environment, forcing newairspace developments to be designed in such a way that are not ideal from the perspective of applying AirTraYc Control, nor from the operating eYciency of the airspace users.

The established consultation process is complex and requires a lot of time, resource and money for aconsultation to be undertaken in compliance with the process. The sheer size and cost of the task may,GATCO believes, deter some Air TraYc Service Providers from attempting to develop their airspace. This isdetrimental, as airspace developments on the whole improve safety, eYciency and capacity. The consultationprocess should be made simpler, thereby allowing for Air TraYc Service Providers to progress developmentsmore easily, especially when there is a safety driver behind the change.

The Guild’s position is that environmental issues should never be permitted to compromise the safety ofAir TraYc Control and aircraft in general. For instance, runway selection for environmental reasons shouldnot be undertaken if it results in a reduction in safety. An example could be a runway being selected withouta Precision Approach capability in marginal weather conditions due to noise considerations.

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Ev 136 Transport Committee: Evidence

3.5 Question 5

How does the management of airspace in the rest of Europe aVect flights into the UK? Is there an opportunityto integrate our plans for changes to airspace management more eVectively with those of other Europeancountries?

GATCO believes that there is an integral link between the UK and the rest of Europe as far as airspaceis concerned. The presentation of traYc between the UK and the adjacent airspace volumes is critical.General flows of aircraft need to be co-ordinated on a regional basis.

Many airspace developments in the UK will have a significant impact on flows of traYc to and fromcontinental Europe and vice versa. Large airspace developments, especially in the South East of the UK or inthe en-route area environment, need to be co-ordinated with adjacent Air TraYc Service Providers. Airspacedevelopment projects are often set up to include the States/Air TraYc Service Providers that will beimpacted. In addition, there are various groups at Eurocontrol where such developments can be discussed.

The Guild supports the concept of Functional Airspace Blocks (FABs), on the proviso that they areestablished to provide clear operational benefits, rather than for other non operational reasons, eg costreduction.

3.6 Question 6

What opportunities are there to apply new techniques and technologies to reduce wasteful flying on indirectroutes and excessive “stacking” while planes wait to land? How can the potential of any such opportunities bestbe realised? Could environmental benefits be gained as a result of such improvements?

There are numerous new concepts and technologies that are in the process of being developed.Programmes such as SESAR will be instrumental in progressing these R&D activities, resulting ininteroperable procedures and systems being rolled out throughout the core European area.

The deployment of Arrival Management (AMAN) systems will assist in smoothing the delivery of traYcinto UK terminal airspace. By metering traYc through fixes, enabled by earlier planning and control ofinbound aircraft, the bunching that currently occurs can be largely eliminated.

Metering can be achieved by Air TraYc Controllers providing tactical instructions, namely speed controlor path stretching, to aircraft. An emerging capability on board aircraft is to operate to a Controlled Timeof Arrival (CTA). For aircraft that have such a capability, the controller would simply issue a time to passthrough the metering fix and the Flight Management System on board the aircraft would then adhere to thisconstraint (assuming it is a realistic one in the first place).

Any residual bunches can be further smoothed by the deployment of techniques such as RNAV PointMerge, which may oVer a viable alternative to the use of the low level holds that are in use today aroundthe busiest UK airports.

The use of Performance Based Navigation, such as Precision Area Navigation (P-RNAV), enables routesto be spaced closer together. This in turn improves the eYciency of the airspace and can raise capacitythrough a given sector. RNP approaches may also oVer an opportunity to undertake simultaneousContinuous Descent Approaches to closely spaced parallel runways, such as those in use at Heathrow. Suchuse of new technology/concepts would enable capacity to be increased whilst reducing the environmentalimpact at the same time.

Whilst some aircraft are currently capable of conducting the procedures outlined above, it is importantthat the vast majority of aircraft are able to do so in the future. For this reason, GATCO encourages theconsideration of applicable mandates in order to enable a position to be reached whereby the vast majorityof airspace users are suitably equipped.

3.7 Question 7

In relation to the redesign of UK airspace, is the allocation of the roles and responsibilities of each of theinterested parties—Department for Transport, the CAA, airport operators, NATS, etc—appropriate andclearly understood? Are the structures of the parties appropriate for undertaking the roles that they should play?

Through its regular liaison with the Department for Transport, the CAA, NATS, other Air TraYc ServiceProviders and airport operators, GATCO is in a good position to understand the roles and responsibilitiesthat each of these parties has with regard to the redesign of UK airspace. However, the Guild can understandwhy other organisations and the public at large may not have this same level of visibility regarding who doeswhat when it comes to airspace redesign.

GATCO notes the extensive eVorts made during recent airspace developments and associatedconsultations to try and engage with organisations and the public and to make them aware of the roles andresponsibilities of the main parties involved. Whilst the Guild welcomes such eVorts at increasing visibilityof the processes being followed, there is a perceived danger that the sheer size of the airspace development/consultation process may get to a point where it becomes very diYcult to progress any change at all.

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3.8 Question 8

Do airspace management considerations delay the planning processes in relation to airport developmentproposals? How will airspace management considerations be taken into account by the proposed newInfrastructure Planning Commission and the relevant National Policy Statements on airport planning?

The Guild is not in a position to provide a detailed answer to the above question as it has limitedinvolvement in planning processes around airport developments. However, the perception is that if airspacemanagement considerations are not taken into account at an early stage in the planning of airportdevelopments, then airspace constraints can have a significant impact later in the process.

GATCO would welcome the inclusion of consideration of the potential impact on airspace and itsmanagement when airports are developing their master plans.

3.9 Question 9

What could be the implications for smaller airfields, recreational flying and helicopters of changes to airspacemanagement to enable safe and eYcient increases in capacity at the UK’s major airports? How should anappropriate balance between conflicting priorities be determined?

There is a finite amount of airspace available in the UK and it is under considerable pressure from a varietyof airspace users, particularly in the South East. There is a pressing need to safely grow capacity at the mainairports in the UK in a manner that minimises the impact on the environment. The limited amount ofairspace makes it a challenge to accommodate the requirements of all airspace users at all times.

Due to this competing demand for airspace, there is a need to ensure that all airspace users have a fairand equitable access to it, as far as is reasonably practicable. Air TraYc Service Providers attempt to ensurefair and equitable access to all airspace users, but the practicalities of ATC mean that it is necessary in someinstances to restrict the use of certain airspace to certain users.

The airspace regulator, Directorate of Airspace Policy, has a key role to play in ensuring that any airspacechange is subject to consultation and that access to airspace is provided on a fair and equitable basis as faras is reasonably possible.

3.10 Question 10

Will it be possible to recruit and train staV in order that airspace changes can be implemented in parallel withadditional airport capacity?

The Guild believes that there are relatively low numbers of ATC staV with the expertise and knowledge toundertake large-scale, often technically complex, airspace developments. In addition, it can be problematicgaining the release of operational controllers from their core ATC tasks to assist in airspace developments.This is due to a general overall lack of qualified Air TraYc Controllers.

This limitation in number of suitably qualified people will make it diYcult to continue progressingairspace developments in parallel with the demand from the drivers of safety, eYciency, capacity and theenvironment.

3.11 Question 11

Who should fund airspace changes? Is there likely to be enough funding to undertake the redesign required tobring about the necessary additional airspace capacity?

Airspace is a national asset. It is used by a wide variety of users, including the military, general aviationand commercial operations. GATCO believes that some changes in airspace that are required because ofnational policy or in order to support government decisions should be paid for from a central fund, in asimilar way to the funding provided for other national infrastructure assets.

Smaller changes to airspace required by specific airports, airspace users or Air TraYc Service Providersshould be funded by either by the instigator of the change or by the end user through existing chargingmechanisms, such as the en-route charging facility.

Airspace development is a fairly costly exercise, due to the necessary conduct of simulations and theconsultation process. However, when compared to the costs of maintaining and developing other nationalinfrastructure assets, the cost of airspace change is put into perspective.

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In order to obtain the perceived safety, eYciency, capacity and environmental benefits from airspacedevelopment GATCO encourages that appropriate levels of investment are made. There are significantchallenges to the development and management of UK airspace in the near future and it will be necessaryto provide appropriate funding and resource to handle these challenges.

November 2008

Memorandum from The 2M Group (AIR 17)

The 2M Group would like to respond to the announcement by the Transport Select Committee on the21st July 2008 that it will be conducting an inquiry into the use of airspace.

This submission reflects the concerns expressed by elected representatives of the 2M group about the wayin which proposed changes in airspace are currently managed in the United Kingdom.

These concerns arise both from the way in which aviation transport policy has been formulated in the2003 Air Transport White Paper and from experience gained from recent proposals for airspace changearound London and The Home Counties—Terminal Control North (TCN).

2M believes there are major flaws in the airspace change consultation and decision making processes. Theflaws remain despite previous comments and recommendations of the Select Committee and a root andbranch review of the CAA by the Government as recently as July this year. 2Ms concerns can be summarisedas follows:

(a) Lack of democratic accountability for airspace change decisions.

(b) Lack of a true appeal process before an independent tribunal in relation to DAP decisionsfollowing airspace change consultation.

(c) No apparent vision for future airspace needs.

(d) Fundamental flaws in the NATS/CAA airspace change consultation process.

2M has detailed concerns about each of the above matters which are amplified below.

(a) Lack of Democratic Accountability

The Select Committee has noted this anomaly on a previous occasion in 2006. Airspace changes can anddo adversely aVect the quality of life of thousands of UK citizens. Decisions of this magnitude should besubject to close parliamentary scrutiny and the accountability for the impact of such changes belongs at anappropriate level in government. 2M believes such responsibility should rest with the Secretary of State forTransport. The current arrangements which vest the executive decision for airspace changes with anunelected CAA oYcial (The Director of Airspace Policy) are considered undemocratic. The fact that DAPappointments are made by the Secretary of the State under published guidelines does not in the view of 2Mprovide the required amount of accountability. 2M believes that in this respect the Transport Act 2000 isbadly drafted and should be amended.

(b) Lack of Appeal Process to Air Space Changes

This is a related point on natural justice on which the select committee has also previously commented.Currently it is only possible for potentially aggrieved parties to a proposed airspace change to challenge theproposals by way of Judicial Review. As both the committee and the subsequent Pilling Report haveconfirmed the Judicial Review process is limited in scope. Few applicants succeed where the courts judgethe challenge to be on merits issues or matters of scientific debate or opinions between experts.

An example of the diYculties that were faced by potential litigants in the recent TCN consultation relatesto the use by NATS of out of date noise information and failure to base its assessment of noise impact onthe latest government noise study. For this consultation NATS relied the current (2007) version of CAA 725“Guidance on the Application of the Airspace Change Process” in order to formulate an environmentalimpact assessment for the TCN proposals. However CAP 725 relies on 25-year-old research with respectto community annoyance and aircraft. There is increasing evidence (including the government’s own 2007ANASE study) to suggest that people are more sensitive to aircraft noise than was the case 25 years ago.This also applies to the perceived impact of aircraft, even at quite high altitudes, on tranquil areas whichbecome newly overflown on a regular basis. Conventional wisdom on this issue as described in CAP 725 isnow out of date.

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(c) Flawed Airspace Change Consultation Process

The Select Committee has also previously commented on the Airspace Change consultation process. 2Mis concerned that the NATS promise of a “new style” consultation in 2008 simply did not materialise in therecent TCN consultation. The consultation documentation was impenetrably complex for local people. Itwas also beyond the levels of expertise and comprehension of many local authority oYcers. Thedocumentation was in fact very similar to that produced by the 2006 Terminal Control South West (TCSW)proposals in 2007.

The TCN consultation was further complicated by NATS relying on local authorities to in eVectcoordinate local consultation. NATS personnel unhelpfully refused to attend local public meetingsorganised by local authorities, instead oVering to “brief” senior local authority oYcers on the proposals.However much of the documentation was so complex that it could not be unpacked by the local authorityoYcers concerned within the timescale allowed for the consultation. A number of local authorities incurredexpenditure in employing consultants to work through the vast amount of data on noise for example in orderto understand what impact the proposals were likely to mean in noise terms for communities newlyoverflown. Arguably the TCN consultation did not even comply with the NATS guidelines as set out in CAP725, no alternative solutions being oVered to the main proposal. For example no investigations appeared tohave been made into the possibilities of “stacking ” aircraft beyond the UK coast rather than over land.

(d) Lack of Vision for Airspace Requirements

2M is concerned that changes in UK airspace are being made in piecemeal fashion, often with whatappears to be for minimal gain in capacity but to the detriment of many who find their homes and areastranquillity adversely aVected by overflying aircraft. Meanwhile the bigger picture in terms of what will needto happen in order to realise the sort of airspace capacity envisaged in the Air Transport White Paper(ATWP) remains outside the public domain.

Many communities will it seems remain in the dark about future airspace changes until an airportoperator decides to submit a formal planning application for terminal or runway capacity. It seems that itis only at this time that indicative airspace change proposals may be identified as part of the EnvironmentalImpact Assessment. However air space change assessments currently fall outside of the matters to bedetermined by an inspector through the planning inquiry process with NATS/CAA conducting a separateconsultation within the CAP725 assessment framework. This in eVect means that airspace proposalsproduced for environmental assessment purposes can only ever be regarded as indicative and the extent towhich the merits of the proposals can be tested through the public inquiry process is questionable.

The Government has recently consulted on a range of initiatives for expanding Heathrow. These includeproposals for the airport operator to adopt “Mixed Mode” operations. It is believed that this could happenas soon as 2010. Currently no information has been put in the public domain to inform residents whatairspace changes will be required should the go ahead for mixed mode be given.

2M is also concerned that the potential future influence of the European airspace agency (Eurocontrol)over UK airspace has not been spelt out in either the ATWP or any of the recent government consultations.Currently there appears to be little joined up thinking between the UK aviation policies based uponexpansion and the EUs plans for airspace provision. 2M believes that a Master plan is therefore requiredfor future airspace provision.

October 2008

Memorandum from Great Thurlow Parish Council (AIR 18)

We hereby submit our observations as follows:

1. Points of acceptance.

2. Objections.

3. Suggestions.

4. Conclusion.

1. Points of Acceptance

(a) As a generalisation we accept the necessity for civil flying and the opportunities created for cheapair travel and employment.

(b) We accept that safety is of prime importance and emergencies are excepted.

(c) We accept that the location of various airports is fixed.

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2. Objections

The area of contention for us is the principle of “stacking”. We feel that to “pile up” a number of aircraftin a “hold” over a very specific and local area is both anti-social and unnecessary. Specifically we areconcerned by the plan to create the hold for the Western Approach to Stansted. The disturbance over anarea recognised for its peace and tranquillity will be unacceptably intrusive and detrimental to the localcommunity, tourism and the extensive and valuable equine industry.

Stacking results in a notable decrease in quality of life for a concentrated few. We are prepared to suggestalternatives to stacking that would result in a barely perceptible diVerence in air traYc to a larger numberof people on the ground.

3. Suggestions

(a) Our suggestions for solving the problems of stacking commence with the basic fact that Stanstedis only some 40 miles from the coast. At a speed of 240 miles per hour this is only about 10 minutesflying time. Are we to believe that the air traYc controllers do not know before those 10 minutesthat an aircraft will be early? The answer therefore must be that a turn or circuit could be madeover the sea, especially as the greatest proportion of flights into Stansted are coming from Europe.

(b) If you claim that the sea is too far from Stansted, why not “take a turn” over a non specific area?The air space over East Anglia is vast and the area is multiplied many times if you use it in layers,say tenfold, in two thousand feet increments from 7K to 27K. The region is not that saturated withair traYc, particularly as you claim stacking will only be used occasionally at peak times. If allaircraft were fitted with transponders to fly over say 5000 feet, air traYc control would know wherepotential problems were. This would mean that the chances of any specific area having more thanone aircraft overhead for an unacceptable period would be minimal.

(c) In anticipation that both of the above suggestions answers to the above are unacceptable, we oVera further option for consideration—create a “holding zone”, say five miles wide, either side of theapproach flight path and allow aircraft to circle (hold) in a number of sites progressively along theflight path. In layman’s terms rather like the eddies behind an eights rowing boat at speed (foureither side). We enclose a very basic plan to show how an area of about ten miles by forty miles,astride the approach flight path could provide eight “holds”, those to the left are suYxed L andthose to the right are suYxed R. The number refers to the height in feet. It would be possible tooverlay a second holding zone with the eight say four thousand feet higher, ie AR9, BR11, CR15etc. From an operating viewpoint, by definition no aircraft would be on the flight path duringholding operations; no aircraft would be more than five miles from the approach flight path,aircraft would “move along” holding zones from D to A and at the same time descend inincrements of 2000ft to the airport as called by air traYc control. This simple scheme generatessixteen holds thus greatly diluting the intrusion on the ground. The areas that would be aVectedby holding noise are already adjacent to the existing flight paths and are therefore already subjectto some disturbance.

4. Conclusion

We apologise for the “layman’s” nature of this submission but our observations are based on commonsense. We recognise that these proposals would need adjusting and modifying by the experts but are oVeredas a basic starting point as a preference to a stack.

We do not feel confident that NATS have explored every option to avoid stacking and they have takenthe easy, quick and previously accepted option. With greater problems, better solutions are needed.

October 2008

Memorandum from the National Trust (AIR 19)

Summary

1. The National Trust welcomes the Committee’s inquiry into the use of airspace. Over the past year theNational Trust has been actively involved in discussions with the National Air TraYc Service (NATS), theCivil Aviation Authority (CAA), the Department for Transport, Local Authorities and many localcommunity and environmental organisations regarding the impacts of the proposed changes and the longterm future of airspace management and aviation growth.

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2. The current TCN proposals would have a direct impact at a number of National Trust propertiesincluding Osterley Park, London; Wimpole Hall and Wicken Fen, Cambridgeshire; Ickworth Hall Estate,SuVolk and the Ashridge Estate and Coombe Hill in Buckinghamshire. These sites receive approximately1,500,000 visitors a year who value these places for their tranquillity and the opportunity they oVer forpeople to get away from the intensity of modern life and ‘recharge their batteries’.

3. The National Trust is particularly concerned that the current proposals will significantly underminepeople’s ability to benefit from these tranquil places and that the frameworks within which airspace ismanaged do not adequately address this.

4. In order to reconcile an increasingly important, complex and controversial area of public interest TheNational Trust considers that there is a need for the following key actions:

(i) A new participative public debate about the positive and negative impacts of aviation expansionand airspace management which would lead to a new set of policies and guidance with broad publicsupport and understanding.

(ii) The development of a new model for assessing the environmental impacts of aviation and airspacemanagement including an improved methodology for measuring tranquillity which reflects thepublic’s view on what is intrusive rather than relying wholly on scientific measures.

(iii) An immediate assessment of the potential impacts of ‘gate to gate’ and other related technologyon public green spaces and sensitive natural and historic environments in order that these factorscan be fully embedded in the development and implementation of any new air traYc controlsystems and processes.

(iv) A review of the role, responsibilities and ownership of the National Air TraYc Service.

(v) The modernisation of the structures and accountability of the Civil Aviation Association in linewith the recommendations of the Pilling review including the introduction of a clear responsibilityin relation to the environment.

5. At the heart of many of these issues is the unsustainable growth in aviation. The National Trustendorses the findings of the Sustainable Development Commission report, Breaking the Holding Patternand believes that there is an urgent need for a rethink of the Government’s aviation policy and its impacton people’s quality of life. By taking a step back and examining these issues the proposed review will helpGovernment take account of the aviation sector’s contribution to the UK’s climate change targets as wellas balancing the wider set of public policy issues.

The Role of the National Trust

6. The National Trust is Europe’s largest conservation body with over 3.5 million members, 50,000volunteers, an annual turnover approaching £400 million and a presence throughout England, Wales andNorthern Ireland. We currently protect and manage on behalf of the nation over 250,000 hectares ofcountryside and 1,100km of coastline together with a significant proportion of the country’s designated sitesand buildings of historic significance. This includes six World Heritage Sites, over 6,000 listed buildings,1,200 scheduled ancient monuments, 149 registered museums and 8% of all registered historic parks andgardens.

7. Our property portfolio is hugely diverse, ranging from some of the nation’s most iconic and well-known sites to some of the more ordinary and everyday elements of our rich and diverse cultural heritage.

Demand and the White Paper

8. The National Trust’s discussions with NATS and our response to the consultation on changes to theTerminal Control North area have highlighted our concern that the current proposals for the managementof airspace have not adequately taken account of the increase in flight numbers that would be associatedwith airport expansion, whether increasing the number of runways at Heathrow and Stansted or increasingrunway capacity through changing the operation of existing runways.

9. We are extremely concerned that given the four years it has taken NATS to develop the existingconsultation proposals which only cope with incremental growth, the further expansion of aviation will seesignificant impacts on highly valued green spaces and sensitive historic environments.

10. Assuming safety is not to be compromised, under either the incremental or step change growthplanned within the Air Transport White Paper, it seems likely that even less weight will be given to the impactof aviation on natural green spaces or people’s quality of life generally when managing airspace in the future.

11. The National Trust believes this is wrong and that there a number of public interest issues beyondsimply satisfying the demand for air travel and that greater weight should be given to these factors whenconsidering the routes and density of flights as this would better reflect the balance of public interest.

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Safety and Military uses

12. The National Trust is not well placed to comment on the issue of the interface between military andcivil aviation arrangements other than to say that military uses of airspace also have impacts on people’squality of life and the tranquillity of green spaces across the UK. It is therefore important that the impactof all airspace users are considered together rather than in isolation.

13. We recognise the paramount importance of maintaining safety standards however we would draw thecommittee’s attention to the wider impacts that may result, in particular the impacts on people’s quality oflife and the loss of tranquillity in the countryside and at important historic sites.

14. In order to balance these interests it may be necessary to more fundamentally review the numbers ofaircraft using UK air space.

Planning and Regulation

15. The National Trust believes that the current approach to planning and regulating the use of UKairspace is inadequate and has fallen well behind the standards adopted in other areas of public policy suchas the land use planning system.

16. The current policies and guidance have insuYcient detail on:

(a) a metric for appraising tranquillity,

(b) a full and robust methodology for the appraisal of environmental impacts,

(c) the requirement for an evidence base (as would befit an Environmental Statement), and

(d) consideration of “issues and options” as would be required if this were a land-use policy matter,which reveal alternatives and give appropriate weight to a variety of options, including nochange options.

17. We believe that a far better system is required on the formulation of airspace routing and that anecessary pre-requisite of this is that a more appropriate and thorough set of policies and guidelines is putin place.

18. These guidelines would need to provide a framework for the full and frank appraisal of impact uponissues such as landscape quality, numbers of people aVected and impact on tranquillity.

19. The key guidance document in relation to airspace management change is the Civil AviationAuthority’s Airspace Change Process (CAP 725). Whilst we recognise that the guidance does begin toaddress some of the issues highlighted above it does not provide suYcient balance or clear guidance onweighting and there is still an overarching assumption that change to facilitate increased capacity in the skiesis a good thing.

20. The National Trust supports the fact that CAP 725 Appendix B refers to the guiding principles of thelatest UK Sustainable Development Strategy (UK SDS). In section 1 para 8 the guidance states that for apolicy to be sustainable it must reflect all five of the guiding principles of the UK SDS.

21. The TCN proposals will be an interesting test case for the strength of the guidance. We cannot seehow the significant impact of these proposals on open green spaces, the lack of rigour applied to assessingthe impacts of noise on tranquil areas, the lack of detailed consultation on the potential impacts and theincrease in the number of people aVected by aircraft noise would respect any of the principles of:

— living within environmental limits;

— ensuring a strong, healthy and just society;

— achieving a sustainable economy;

— promoting good governance; and

— using sound science responsibly.

22. We have also been surprised by the lack of any real requirement to put forward options or alternativesincluding an assessment of the no change option. For example, it would have been possible to have presentedan option which highlighted the advantages and disadvantages of not making changes to the continuousdecent approaches to Stansted which under the current proposals will have a significant impact on westLondon.

23. The proposals could also have looked at changes to the Bovingdon stack which could have given moreflexibility to mitigate the impacts over the Chilterns. Whilst we understand that managing the airspace iscomplicated this should not be an excuse to operate on the very edge of the guidance and to provide noopportunity for the public or a publicly accountable body to make a judgement on which options are in thewider public interest.

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24. The National Trust understands that piecemeal development will lead to subsequent redesigns andthat due to the complexity of the airspace small changes in one area could result in significant change andimpact elsewhere.

25. We would again the highlight the importance of a more robust methodology for assessing impactsand for a much greater degree of public engagement in order to better understand how the public interestis best served.

The Effects of Aircraft Noise and Emissions

26. One of the factors raised in the recent work of the Sustainable Development Commission is the lackof agreement regarding the assessment of noise. The National Trust is extremely sceptical about therelevance of current methods used to measure noise. The Trust’s case, put forward at the recent PublicInquiry into the expansion of Stansted Airport, is that the increase of noise as indicated by noise contoursbased on decibels, takes no account of the impact in relation to the human appreciation of the ambient noiselevel, nor the frequency of that impact. For instance, an increase in noise level in a built-up area where thebackground noise is already subject to noisy influences would have a far less impact on the population thanwhere the same level of increased noise to be transferred to a tranquil area of countryside.

27. As the Campaign to Protect Rural England has stated in its publication Saving Tranquil Places,published in 2006, “these tranquil places are important for our mental and physical health, our wellbeingand our economy”. A survey of 1,300 countryside visitors was used to explore people’s perceptions oftranquillity and the results informed the CPRE publication. The survey revealed that seeing low flyingaircraft, and hearing low flying aircraft, were in the top eight responses of intrusions into tranquillity.

28. The National Trust recognises that the relationship between noise impacts, air quality and emissionsis a complex one. For example flying aircraft in straight lines is more eYcient in terms of fuel consumptionwhich reduces harmful emissions but might have a greater impact on tranquil areas just as reducing noiseimpacts by increasing the rate of ascent from an airport may worsen local air quality.

29. Striking the right balance will always be diYcult in these circumstances and it is because of thiscomplexity that the National Trust believes there should be a more widespread and active dialogue designedto develop a new set of policies and guidance for making these judgements.

30. We would argue that the best people to help get the balance of public interest right are the public. Asan appropriate approach to a complex area of public interest we would point to the relatively recent debateand formulation of policy around GM crops which was informed by an active public engagementprogramme.

The Application of New Techniques and Technologies

31. The National Trust understands that there may be environmental gains from the introduction of newtechnology, however, we would highlight the complexity of these environmental issues and would also drawthe committees attention to possible negative impacts of introducing technological innovation. Forexample, whilst we understand that implementing PR-NAV may bring advantages in the eYcient and safemanagement of air traYc the introduction of or changes to PR-NAV routes in relation to easterly operationsfrom Heathrow to the North and North East would have impacts on Osterley Park and the residents of theLondon Borough of Hounslow.

32. Technologies such as PR-NAV are designed to more accurately control the path of aircraft. Throughdiscussions with the CAA we understand that this increased emphasis on predetermining flight paths is likelyto the only way that airspace can be managed should aviation growth continue at its current rate.

33. We understand that within the next few years it is likely that a “gate to gate” system will be developedwhereby aircraft will be given predetermined and computer controlled routes in space and time. As they pullback from the gate aircraft will fly this exact route until they pull up to the arrival gate. Whilst we understandthat this would enable the eYcient use of airspace we are extremely concerned that such a system will takeeven less account of what is below the aircraft.

34. If such a system were to operate we believe that there should be a widespread public debate about theadvantages and disadvantages of concentrating or dispersing aircraft and that in developing the “slots” inspace and time there should be due regard for the impacts these will have on the public and the natural andhistoric environment below.

Roles and Responsibilities

35. Whilst a thorough reading of CAA CAP725 makes it reasonably clear where the roles andresponsibilities of the various bodies lie, the National Trust considers that the structures or the parties arefar from appropriate in terms of undertaking the roles that they are asked to fulfil and that the governancearrangements and degree of accountability within the sector are not appropriate for the scale and impact onpublic life.

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36. In relation to the National Air TraYc Service who are the principle proposer of airspace changes weare particularly concerned by the degree of influence exerted by the airlines and airport operators throughtheir part ownership of the organisation.

37. We question whether it is appropriate that an organisation which is responsible for managing theeYciency of airspace and which therefore exerts significant influence on the quality of millions of people’slives across the UK should be part owned by the aviation industry who have almost no responsibility oraccountability for the impacts that their businesses have on the public’s quality of life in relation to noiseand the value placed on tranquil areas.

38. Whilst we understand that a “Chinese wall” exists within NATS it also surprising that they shouldbe asked to try and balance a wide range of public interests in terms of their quasi regulatory role in en-routeairspace management whilst at the same time having to compete for the business, of their own owners, interms of managing airspace movements within airport boundaries.

39. In relation to the Civil Aviation Authority the National Trust believes that whilst the organisation isclearly attempting to act in the wider public interest the organisational structures and accountability withinthe organisation are not fit for purpose given the growing impacts of aviation on public life.

40. The National Trust considers that the recent Report of the Strategic Review of the CAA by Sir JosephPilling is a thorough assessment of the situation and we would support his recommendations in relation toimproving the structures and accountability of the CAA.

41. In particular we welcome the recommendation that the CAA should have a specific responsibility inrelation to the environment. In order for it to successfully discharge any such duty we would recommendreviewing the way in which the CAA engages with the public and environmental organisations whethergovernment agencies or NGOs.

42. Particular emphasis might also be given to the future make up of any executive or non-executiveboards in order to ensure that the balance of environmental and social interests are represented at astrategic level.

The Planning System

43. The National Trust is not aware that air space management considerations delay the planningprocess, however, we do believe that airspace management issues should form an integral part of the processby which any planning decision is determined.

44. It would seem to make little sense to go to the expense of a major planning application with theassociated public inquiry without fully understanding whether the development is deliverable in terms ofairspace management or whether the required airspace management changes would have an inappropriatelevel of impact on people’s quality of life.

45. The National Trust is also interested in the relationship between airspace managementconsiderations, the new IPC and the development of any NPS. We consider that airspace managementshould certainly be a consideration in the development of any NPS and that airspace management impactsshould be a consideration for any developments considered by the IPC.

The Implications for Smaller Airfields

46. The impacts of smaller aircraft and airfields on the tranquillity of green spaces should not beunderplayed. The low altitude and slow speed of these aircraft mean that they can have a disproportionatelyhigh impact in terms of noise.

October 2008

Memorandum from the New Forest National Park Authority (AIR 20)

1. Summary

— The New Forest National Park Authority’s main concerns about current and future projected useof airspace relate to the impact on National Parks and other protected landscapes.

— The existing government guidance to the Civil Aviation Authority on environmentalconsiderations, which is now six years old, must be updated to reflect the protection aVorded toNational Parks in statute.

— The airspace change process would also benefit from greater clarity regarding the roles of theDepartment for Transport, the Civil Aviation Authority, the National Air TraYc Services, theinvolvement of wider stakeholders in the decision making process, and the 12 monthoperational review.

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2. Introduction

2.1 The New Forest National Park Authority welcomes the Committee’s inquiry into the use of airspaceand the opportunity to submit evidence. The National Park Authority has recently been involved in theSustainable Development Commission’s review of aviation, culminating in the recent publication ofContested Evidence: The case for an independent review of aviation policy. The work of the SustainableDevelopment Commission highlights the need for dialogue before major decisions on the future of air travelin the United Kingdom can be made, and to this end the Transport Select Committee’s inquiry isparticularly timely.

2.2 The New Forest National Park is located beneath some of Britain’s most congested airspace and theNational Park Authority has recent experience of the airspace change process, following the Civil AviationAuthority’s endorsement earlier this year of the Terminal Control South West (TCSW) airspace changeproposals. This change has resulted in the area of controlled airspace being extended over some of the moretranquil areas of the National Park, allowing aircraft to cross the New Forest at heights as low as 5,500 feet.The National Park Authority prepared evidence detailing the impacts the airspace change would have onthe special qualities of the New Forest, and this experience highlighted a number of major areas of concern.

3. National Parks and Aviation Policy

3.1 Although the special status aVorded to National Parks and other protected landscapes in nationallegislation is mentioned within existing aviation policy, our experience is the impact on a protected landscapeis aVorded little weight in current decision making. The Civil Aviation Authority is required under theTransport Act 2000 to take account of government guidance on environmental objectives in carrying out itsair navigation functions. This guidance to the Civil Aviation on environmental objectives relating to theexercise of its air navigation function was issued by the Department of Transport in 2002, stating,

“The Government’s aim is to give stronger protection to the most valued landscapes in designatednational parks and areas of outstanding natural beauty. Therefore, whenever practicable the DAPshould pursue policies that will help to preserve the tranquillity of the countryside where this does notincrease significantly the environmental burdens on congested areas.”—paragraph 46.

3.2 Section 62(2) of the Environment Act states that in making decisions that could aVect National Park,relevant bodies (including the Civil Aviation Authority) must have regard to the two statutory National Parkpurposes as set out in section 5 of the National Parks and Access to the Countryside Act 1949, as amendedby section 61 of the Environment Act 1995, namely:

— to conserve and enhance the natural beauty, wildlife and cultural heritage of the National Park;and

— to promote opportunities for the public understanding and enjoyment of the special qualities ofthe National Park.

Clearly decisions over the use of airspace above National Parks can have significant impacts on thedelivery of the two statutory Park purposes, and this has been highlighted by the recent Terminal ControlSouth West Airspace decision aVecting the New Forest National Park.

3.3 The National Park Authority commends a number of recommendations in Sir Joseph Pilling’s recentindependent review of the Civil Aviation Authority (2008). In particular, the Authority believes there is anurgent need to update the current government guidance on environmental objectives (which is now six yearsold), and the need for a clearer framework on how the CAA should reconcile competing considerations.

4. Inquiry Questions

4.1 Given the Authority’s recent experiences of the airspace process, responses are given to the followinginterlinked Committee questions.

Is the current approach to planning and regulating the use of UK airspace adequate?

How are the eVects of aircraft noise and emissions taken into account when changes are made to the use ofairspace? Who should be consulted? How should the balance between conflicting interests be struck?

4.2 The Authority’s recent involvement in the airspace change process leads it to conclude that the currentapproach to regulating airspace is inadequate in terms of the level of protection aVorded to National Parksand other nationally designated landscapes. Despite their legal duty to have regard to the statutory NationalPark purposes, the Civil Aviation Authority endorsed the TCSW airspace change that has resulted in aircraftcrossing the National Park at heights as low as 5,500 feet. This decision places no limits on aircraft numbersusing this new area of controlled airspace (although hours of operation are currently restricted), and theexpansion proposals at Bournemouth and Southampton Airports will result in increasing aircraftmovements at low levels over the New Forest National Park. The National Park Authority’s detailed noiseimpact assessment concluded that the impacts of the airspace change would be audible across the whole partof the National Park not previously overflown.

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4.3 The Authority is concerned that the existing Department for Transport guidance on environmentalobjectives (2002), which the CAA is specifically required to take into account, could be interpreted by theregulator in such a way as to allow it to reach this decision. In this context, the National Park Authoritywelcomes a number of recommendations in Sir Joseph Pilling’s report on the Civil Aviation Authority, inparticular:

(i) the Secretary of State should provide a framework which oVers guidance to the CAA on how toreconcile environmental and other competing considerations; and

(ii) the Department for Transport’s guidance on environmental objectives in relation to the CAA’s airnavigation functions should be reviewed to ensure that it continues to be up to date.

4.4 The New Forest National Park Authority would strongly support the Government taking measuresto strengthen the alignment of aviation policy with wider government policy on protected landscapes. Thecurrent government guidance to the Civil Aviation Authority acknowledges the special status of NationalParks, but goes no further. The guidance should be amended to ensure consistency with the Civil AviationAuthority’s statutory duty to have regard to the National Park purposes when making decisions. Althoughthis duty does not override other obligations or considerations, it is intended to ensure that the purposes forwhich National Parks have been designated are fully recognised in reaching decisions that have an impacton them.

4.5 The whole airspace change process also lacks accountability under current arrangements. CivilAviation Authority guidance on the application of the airspace change process (CAP 725, March 2007)makes it clear that an operational review should take place 12 months after the introduction of an airspacechange, and that the Director of Airspace Policy “…may invite organisations aVected by the change toparticipate or contribute to the review . . .” The Civil Aviation Authority’s Airspace Charter (CAP 724,November 2007), confirms that, “. . . in particular it will be necessary to assess if the anticipatedenvironmental benefits have been delivered.” The National Park Authority wrote to the Civil AviationAuthority earlier this year to request involvement in the operational review of the Terminal Control SouthWest Airspace Change, given the legal duty the CAA have to have regard to Park purposes in makingdecisions, but this request was turned down. The Authority therefore has little confidence that the reviewwill comprehensively review all of the environmental impacts of the change.

Is the allocation of roles and responsibilities of each of the interested parties—Department for Transport, theCAA, airport operators, NATS etc—appropriate and clearly understood?

4.6 The Authority’s involvement in the consultation and decision making process for the TerminalControl South West airspace proposals also illustrated the current lack of clarity over the roles of the CivilAviation Authority, the National Air TraYc Services (NATS) and the Department for Transport. Therelationship between NATS, as the proposer of airspace changes, and the Civil Aviation Authority—theregulatory authority responsible for approving changes—appeared close and external bodies looking tocomment on the process had no sense of independent accountability. It was also not clear how the CivilAviation Authority’s Environmental Research and Consultancy Department (ERCD) could haveundertaken an independent environmental assessment of the airspace proposals while still being under thewing of the Civil Aviation Authority.

4.7 In terms of the role of the Department for Transport, the National Park Authority and many otherswrote to the Secretary of State for Transport in early 2008 requesting that the Terminal Control South Westairspace decision be referred to her given the potentially significant detrimental eVect on the environmentthe changes would have. This was seen as the only means of gaining public accountability of the airspacechange process, but the request was again not acceded to.

5. Conclusion

5.1 The Sir Joseph Pilling Review and the Transport Select Committee inquiry provide a timelyopportunity for the current shortcomings in airspace regulation to be addressed. The protection aVorded toNational Parks and other nationally designated landscapes should be given the highest priority ingovernment aviation and airspace policy. The opportunity should also be taken to review the airspacechange procedure to ensure environmental considerations are given due weight through a transparent andpublicly accountable process.

October 2008

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Memorandum from the Department for Transport (AIR 21)

1. The Department for Transport (“the Department”) notes that the House of Commons TransportCommittee is conducting an inquiry into the use of airspace. The Department takes a keen interest in thisissue whilst recognising that the planning and regulation of airspace is primarily the responsibility of theDirectorate of Airspace Policy (DAP) within the Civil Aviation Authority (CAA), the independent aviationregulator.

2. The Future of Air Transport White Paper (“the White Paper”), published in 2003, set out theGovernment’s strategic framework for the development of air travel over the next 30 years. This balancesprojected travel demand from business and leisure sectors and the requirements of the UK economy withthe need to have regard to environmental consequences of air travel. This sustainable approach:

— recognises the importance of air travel to our national and regional economic prosperity, and thatnot providing additional capacity where it is needed would significantly damage the economy andnational prosperity;

— reflects people’s desire to travel further and more often by air, and to take advantage of theaVordability of air travel and the opportunities this brings;

— seeks to reduce and minimise the impacts of airports on those who live nearby, and on the naturalenvironment;

— ensures that, over time, aviation pays the external cost its activities impose on society at large—inother words, that the price of air travel reflects its environmental and social impacts;

— minimises the need for airport development in new locations by making best use of existingcapacity where possible;

— respects the rights and interests of those aVected by airport development; and

— provides greater certainty for all concerned in the planning of future airport capacity, but at thesame time is suYciently flexible to recognise and adapt to the uncertainties inherent in long-termplanning.

3. The Government recognised that additional airport capacity would need to be matched by acorresponding increase in airspace capacity. That is why we looked to the CAA to bring forward a structuredprogramme for the redesign of UK airspace that would help protect safety standards, relieve currentconstraints, take account of environmental impacts and accommodate the forecast increase in air transportmovements where additional capacity was supported.

4. In December 2006, the Government published the Future of Air Transport Progress Report (“theProgress Report”) setting out progress in key areas. In terms of airspace capacity, it recognised that theDepartment would consider, with the CAA and NATS, the air navigation services provider, the impact offorecast growth on the South-East airspace as a whole in the period up to 2030.

5. The Government remains committed to the strategy set out in the White Paper which strikes the rightbalance between economic, social and environmental goals. We welcome this opportunity to set out howairspace capacity issues are being addressed.

6. The Memorandum follows the general order but with some grouping of the questions on which theCommittee has invited evidence.

What changes to the management of airspace could be required as a result of the additional airport capacityoutlined in the 2003 White Paper? Are the White Paper’s projections for increased passenger demand stillaccurate? Are all the measures to provide for increased passenger demand likely to be implemented?

7. The CAA’s DAP is responsible for the planning and regulation of all UK airspace and, in so doing,takes account of air passenger demand forecasts produced by the Department.

8. The forecasts of UK air passenger demand underpinning the White Paper were updated in the ProgressReport. This noted that the 2003 forecasts had accurately predicted demand to 2005, and showed theforecast of significant growth in air passenger demand was robust to a range of sensitivity tests, includingvariations in economic growth and oil prices. The forecasts were again updated with latest data in the 2007UK Air Passenger Demand and CO2 Forecasts report, which confirmed the forecast of significant demandgrowth. The 2008 CAA report ‘Recent Trends in Growth of UK Air Passenger Demand’ concluded thatrecent slower growth in air passenger demand is due to short term cyclical factors, not a change to the longerterm trend of growth. The Department expects to publish new forecasts, taking account of latest economicprojections, alongside the decision on the future development of Heathrow later this year.

9. The White Paper also invited airport operators to produce new or revised master plans explaining howtheir modernisation and development proposals would help inform regional and local planning processes,and how they would take account of local impacts and the wider environmental impacts of air travel. The

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White Paper recommended that these should include details of the necessary environmental controls andmitigation plans, proposals for improved surface access, and, where appropriate, measures to address blight.In most cases, the masterplans did not address airspace requirements. The Department is aware that CAAand NATS are of the view that, were all of the south-east airport development plans to come to fruition,there would not be suYcient airspace capacity to accommodate the scale of predicted growth on the basisof current and predicted technology. However, airport masterplans are aspirational and it is unlikely thatall airport developments will be implemented. Furthermore, we have worked closely with CAA and NATSto ensure that proposals for development at Heathrow and Stansted are fully workable.

10. Given the above, it is diYcult at this stage to quantify precise changes to the management of airspacethat could be required as a result of the additional airport capacity outlined in the White Paper.

Can safety be maintained as airspace is increasingly utilised? Is there a suitable interface between military andcivilian arrangements for air traYc control?

11. Aviation safety is the top priority for the Government, regulator and air navigation service providers.The CAA’s Safety Regulation Group (SRG) works in partnership with the industry to continually improveaviation safety in the UK and, in partnership with the European Aviation Safety Agency (EASA), acrossEurope. SRG’s strategic objective is to ensure that the UK’s excellent aviation safety performance is, at least,sustained at its present level. Its independent rigorous safety regulation of all UK air navigation serviceproviders is increasingly becoming the world-wide model.

12. The European Commission published the Single European Sky II (SES II) package in June 2008(Com(2008) 389). This package included the objective of establishing a single safety framework for Europe,centred on EASA, in order to improve safety levels alongside the increase in air traYc. EASA was establishedin 2003 and currently has responsibility for setting the regulations and standards for the airworthiness ofaircraft, air operations and flight crew licensing. As part of the SES II initiative the Commission hasproposed an amending Regulation to extend EASA’s remit to the safety of aerodromes, air navigationservices and air traYc management. The Department is seeking views by 20 October on the proposedextension of EASA’s remit to the safety of aerodromes, air traYc management and air navigation services.The responses to the consultation will be taken into account in formulating the UK’s negotiating positionduring the legislative process in the Council and the European Parliament.

13. Under the Transport Act 2000, the CAA has an obligation to facilitate the integration of civilian andmilitary air traYc management. The Civil Aviation Authority (Air Navigation) Directions 2001 require theCAA to oversee the arrangements between a licence holder and the MOD to ensure that air traYc servicescontinue to be provided on a joint and integrated basis. The Joint Air Navigation Services Council (JANSC)is the principal means of achieving this aim. Currently, NATS is the only holder of an en-route licence andthe JANSC acts as the forum for discussing and resolving diVerences of opinion between it and the MOD.The JANSC is chaired by the Director of Airspace Policy. This mechanism is highly eVective in continuingto improve the UK’s joint and integrated civil and military air traYc services to the extent that thearrangements are viewed as the model of civil/military co-operation for Europe. The UK’s civil/militaryinterface is further enhanced by the co-location of civil and military units at the NATS London Area ControlCentre in Swanwick and the Scottish and Oceanic Area Control Centre in Prestwick.

Is the current approach to planning and regulating the use of UK airspace adequate? Would an Airspace MasterPlan covering the period of the White Paper be beneficial? Could a piecemeal approach to individualdevelopments necessitate additional redesigns subsequently?

14. The Government does recognise that airspace is a finite resource. Forecast traYc growth in both UKand European airspace as well as the development of airport masterplans will place increasing capacitydemands on airspace, particularly in the South-East. That is why the Progress Report noted that theDepartment with the CAA and NATS would consider the impact of forecast growth on the South Eastairspace in the period up to 2030.

15. Termed the “Future Airspace Strategy” (FAS), work has begun to set out a strategic plan formanaging the UK’s increasingly busy airspace to deliver safety, eYciency, capacity and environmentalbenefits. This work will necessarily take account of European developments, in particular the developingSES II initiative, its SESAR (Single European Sky Air TraYc Management Research) programme and anyresulting changes in our European neighbours’ airspace management arrangements impacting UK airspacestructure and procedures.

16. FAS aims to ensure that airspace developments are taken forward in a measured and co-ordinatedmanner rather than on a piecemeal basis. However, the airspace policy framework is set by the InternationalCivil Aviation Organisation (ICAO) and increasingly the European Community; the UK must respond, asappropriate, to such international and regional developments.

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How are the eVects [of] aircraft noise and emissions taken into account when changes are made to the use ofairspace? Who should be consulted about such changes? How should the balance between conflicting interestsbe struck?

17. Responsibility for airspace changes procedures falls primarily to the CAA’s DAP in light of proposalsput to them by airspace change sponsors, mainly airports and air navigation services providers. Thisresponsibility extends to ensuring that a thorough assessment of the environmental impact of any proposedairspace change is undertaken during its development.

18. The process for making changes to airspace is governed by the CAA’s Airspace Change Process. CAP724, the Airspace Charter, enables any organisation to initiate a change to airspace arrangements and CAP725 provides further Guidance on the Airspace Change Process. These are explained in more detail inparagraph 37.

19. Following review and consultation, the CAA issued a revised version of the guidance in March 2007.Amongst other matters, the revision provided greater clarity on the roles and responsibilities of an airspacechange sponsor and the decision-maker, greater detail, including a step-by-step guide, on the activities of aconsultation exercise, and substantial detail on the environmental assessment of any proposed changeincluding what impacts should be taken into account, how they should be measured and who should beconsulted.

20. The CAA’s airspace change process reflects the Secretary of State for Transport’s Directions andGuidance to the CAA on the exercise of its statutory duties and environmental objectives. The balance indecision-making rightly sits with the CAA’s Director of Airspace Policy given his statutory duties (see paras33—37).

What could be the implications for smaller airfields, recreational flying and helicopters of changes to airspacemanagement to enable safe and eYcient increases in capacity at the UK’s major airports? How should anappropriate balance between conflicting priorities be determined?

21. The economic value of commercial air transport and its associated public benefit has long beenacknowledged, but the CAA’s recent Strategic Review of General Aviation in the UK has now alsohighlighted the significant economic and social benefits of the wider General Aviation sector which includesboth business and recreational flying.

22. DAP is responsible for ensuring that the needs of all airspace users are reasonably met, taking intoaccount environmental issues. To that end, DAP’s process of consultation on airspace change proposals isperhaps unique in Europe in that all airspace stakeholders have the opportunity to express their views onproposals through the National Air TraYc Management Advisory Committee (NATMAC). This forum has,to date, worked well. Given the economic and social benefits of General Aviation identified in the CAA’sStrategic Review, it is important that all stakeholders continue to strive to ensure that the outcome of anyairspace management change proposals seek to allow all users the maximum use of the airspace that isconsistent with safe operations.

How does the management of airspace in the rest of Europe aVect flights into the UK? Is there an opportunityto integrate our plans for changes to airspace management more eVectively with those of other Europeancountries?

23. EU Member States hold sole responsibility for the design and management of their airspace (bothsovereign and that entrusted to them under the ICAO 1944 Chicago Convention—ie the FIRs (FlightInformation Regions)). However, although each State bears this responsibility, it is coordinated for 25 ofthe EU States under a co-operative agreement within Eurocontrol, the European Organisation for the Safetyof Air Navigation. Proposed national amendments to the design of airspace are loosely co-ordinated underEurocontrol’s Route Network Design group to ensure compatibility of changes.

24. Air TraYc Flow Management (ATFM) for the 38 contracting States of Eurocontrol is performed inentirety by the Agency’s Central Flow Management Unit (CFMU). Although slots at individual airportsare agreed between aircraft and airport operators directly (a commercial arrangement), and Flight Plans (anotice of intention to fly a prescribed route, at a given time and over a given profile) are filed by individualaircraft operators, the capacity of ‘the European ATM system’ to control each flight is determined by theCFMU (a flight safety arrangement). UK operators are therefore treated in flow management regard on thesame terms as all other Member States.

25. Airspace management is a purely national responsibility. Each Member State is empowered to ensuresafe and equitable access to airspace for all groups of users. This responsibility is exercised in diVerent waysbut the overarching principle of the “Flexible Use of Airspace (FUA)” is now mandated by the EU underthe Single European Sky programme. FUA endeavours to make the best use of a limited resource byensuring blocks of airspace are not unnecessarily ring-fenced for specific groups of users for prolongedperiods of time; the UK is considered to be a leader in the application of FUA principles.

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26. SES II, currently under negotiation in Council Working Group, proposes the establishment of a“Network Management Function and/or body” whose ultimate responsibility is yet to be determined butin essence will formalise the existing arrangements for the design, allocation and use of airspace. Thisfunction/body is seen as the next natural step in coordinating design and use aspects of the airspace of allMember States. Eurocontrol is likely to perform this role but it is not anticipated that it will be granted anyauthority over Member States that impinges on sovereign right or ICAO driven responsibility.

27. Under SES, Members States are required to establish Functional Airspace Blocks (FABs) as onemeans of maximising the capacity and eYciency of the wider European ATM network. The UK/IrelandFAB, the first FAB in Europe, was implemented in July 2008 and is designed to deliver real operationaleYciencies regardless of existing national boundaries. Given the UK’s strategic position in managing airtraYc flows between North America and Europe, we are also a co-operative partner in the development ofthe proposed FAB Europe Central (FABEC) involving the airspace of France, Germany, the Netherlands,Belgium, Luxemburg and Switzerland.

What opportunities are there to apply new techniques and technologies to reduce wasteful flying on indirectroutes and excessive “stacking” while planes wait to land? How can the potential of any such opportunities bestbe realised? Could environmental benefits be gained as a result of such improvements?

28. The UK is continuing to push for improvements in aircraft technology and operating procedures tocontinually increase the eYciency and environmental performance of the industry. In terms of airspacemanagement, the White Paper stated that the Government looks to NATS to operate and develop air traYccontrol eYciently, consistent with their overall objectives and, in particular, to seek to minimise stackholding as far as possible, to reduce fuel burn and emissions.

29. Current airspace change proposals under development seek to promulgate techniques such asContinuous Descent Approach (CDA), a quieter and more fuel-eYcient approach for landings, andPrecision Area Navigation (P-RNAV), a means of improving aircraft routings and profiles with resultingreductions in fuel consumption and emissions.

30. Although the removal of stacks would require careful examination to ensure that safety and runwaycapacity were not compromised, increased airport capacity may also reduce the need for stacking. Forexample, depending on the Government’s decision on a third runway at Heathrow, NATS have stated thattheir aim is to explore the possibilities for reducing or even eliminating the need for routine stacking asadvanced air traYc management techniques are gradually introduced. The extra capacity of a third runwaywould help in this.

31. Furthermore, NATS is the first air navigation service provider in the world to declare anenvironmental target, aiming to cut emissions from aircraft under its control by, on average, 10 per cent perflight by 2020 against a 2006 baseline.

32. The UK is also an active supporter and participant in SESAR. Although the project is in itsdevelopment phase (2008–14) with implementation planned from 2014 onwards, we strongly support itsemphasis on the environment with a 10% target reduction in emissions per flight based on shorter routeswith improved flight profiles resulting in reduced fuel burn, reduced emissions and reduced stacking.

In relation to the redesign of UK airspace, is the allocation of the roles and responsibilities of each of theinterested parties—Department for Transport, the CAA, airport operators, NATS, etc—appropriate andclearly understood? Are the structures of the parties appropriate for undertaking the roles that they should play?

Will it be possible to recruit and train staV in order that airspace changes can be implemented in parallel withadditional airport capacity?

33. The CAA’s statutory duties are set out in Section 70(1) of the Transport Act 2000. In exercising its airnavigation functions, the CAA must give priority to maintaining a high standard of safety in the provision ofair traYc services and must carry out its functions in the manner it thinks best to:

— secure the most eYcient use of the airspace;

— satisfy the requirements of all airspace users;

— take account of the interests of any person in relation to the use of any particular airspace or theuse of airspace generally;

— take account of any guidance on environmental objectives given to the CAA by the Secretary ofState;

— facilitate the integrate of civil/military air traYc services;

— take account of the interests of national security; and

— take account of the UK’s international obligations as notified to the CAA by the Secretary of State.

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34. The Civil Aviation Authority (Air Navigation) Directions 2001 and the Civil Aviation Authority (AirNavigation) (Variation) Direction 2004, given under Section 66(1) of the Transport Act 2000, clearly set outthe responsibility of the CAA’s DAP to develop, approve, monitor and enforce policy for the safe andeYcient allocation of UK airspace and the sustainable use of that airspace.

35. In addition, the Secretary of State’s Guidance to the CAA on the Environmental Objectives Relatingto the Exercise of its Air Navigation Functions (2002), sets out the framework within which DAP willdischarge the CAA’s air navigation functions.

36. The Guidance and Directions are designed to ensure that proposals for airspace changes are broughtto the attention of aVected parties, are properly assessed, that environmental impacts are mitigated as muchas possible and that changes are only made where it is clear, after consultation, that an overall environmentalbenefit will accrue or where the airspace management considerations and the overriding need for safety allowfor no practical alternative—this balance in decision-making rightly sits with the CAA’s Director ofAirspace Policy.

37. CAP 724, and CAP 725 clearly identify the roles and responsibilities of airspace change proposer andairspace change decision-maker. A change sponsor is responsible for developing and consulting upon aproposal, ensuring that it satisfies and/or enhances safety, improves capacity and mitigates, as far as ispracticable, any environmental impacts in line with the Department’s environmental guidance to the CAA.The CAA, as decision-maker, assesses a formal airspace change proposal against regulatory requirements,including environmental objectives, and then either approves or rejects the proposal. It is only where theCAA considers that a proposal might have a significant detrimental eVect on the environment that the CAAis required to advise the Secretary of State for Transport of the likely impact. They must also advise of plansto keep that impact to a minimum, and to refrain from making the airspace change without first securingthe approval of the Secretary of State.

38. Clearly, airspace change sponsors need to ensure that they are adequately resourced to develop,consult upon and, subject to regulatory decision, implement a proposed change. Similarly, the CAA mustensure that it is adequately resourced with the necessary expertise to evaluate and decide upon a proposal.To date, appropriate resourcing in the respective bodies has not been a limiting factor in the developmentor decision-making processes for airspace change proposals.

39. Following the independent strategic review of the CAA by Sir Joseph Pilling, the Secretary of Statehas agreed his recommendation that the CAA’s governance be strengthened with the addition of a ChiefExecutive OYcer.

40. The review’s other recommendations remain subject to detailed consideration with a view to theSecretary of State providing an update in the autumn. In airspace terms, recommendations of particular noteinclude that the CAA be given a general statutory duty in relation to the environment, that the duty be setwithin a policy framework from Government oVering guidance to the CAA on how to strike the balancebetween environment and other considerations, that the framework make clear the boundary between theroles of the CAA, the Government and other stakeholders, and that the Secretary of State’s environmentalguidance to the CAA be updated.

41. The Government welcomes these recommendations and the review’s acknowledgement of thechallenge which would be involved in producing an environmental framework for aviation given the rangeof factors to be taken into account—setting out the inter-relationships between safety, the needs of airspaceusers, the economy as a whole, the aviation sector in particular and the environment. Clearly, any suchframework would need to be suYciently flexible to allow airspace change proposals to be considered on theirindividual merits, recognising that a balance would need to be struck between diVering environmentalobjectives as well as wider considerations.

Do airspace management considerations delay the planning processes in relation to airport developmentproposals? How will airspace management considerations be taken into account by the proposed newInfrastructure Planning Commission and the relevant National Policy Statements on airport planning?

42. There is no evidence to suggest that airspace management considerations delay the planning processesin relation to airport development proposals. To date, all airspace change proposals have been implementedby their target date, where regulatory approval to proceed has been granted.

43. The Department’s aim is to establish a suite of national policy statements that will comprise astatement for aviation incorporating the White Paper in a way which meets the Government’s proposedpolicy and statutory requirements for National Policy Statements set out in the Planning Bill. We arecommitted to producing a further progress report between 2009 and 2011, which would provide a goodopportunity to designate the White Paper in conjunction with that report.

44. The Infrastructure Planning Commission (IPC) will deal with decisions on the construction ofinfrastructure and capacity development on the ground; it will not make decisions solely relating to airspacemanagement which remain the responsibility of the CAA under the Airspace Change Process.

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45. In submitting applications for airport development, a preliminary view will need to be taken of thevarious options for airspace configuration and capacity requirements. Those preliminary views will formpart of the application and be subject to the necessary impact assessments. However, the detailed airspacedesign and subsequent consultation will depend on the nature of the airport development for which IPCconsent is granted. Given the timescales for infrastructure development, the airspace change considerationis not a limiting factor in planning timescales—the decision-making phase for the airspace change processis 17 weeks.

Who should fund airspace changes? Is there likely to be enough funding to undertake the redesign required tobring about the necessary additional airspace capacity?

46. Airspace change proposals can be initiated by any body. However, sponsors for change are most likelyto be an aerodrome operator, an air navigation services provider or a combination of these two given that thedriver for change is generally safety or capacity stemming from increased demand, albeit that environmentalconsiderations must be taken into account. Consequently, in line with the “user pays principle”, it is airspaceusers who fund airspace change proposals through aerodrome landing fees and/or air navigation routecharges. There is no evidence to suggest that such funding is likely to be a constraint to developing futureairspace change proposals.

October 2008

Supplementary memorandum from the Department for Transport (AIR 21a)

Further to my appearance before the Transport Select Committee’s inquiry into the use of airspace onWednesday 22 April, I agreed to write to the Committee detailing any initiatives within the Government’sBudget announcement of the same day which would impact upon the Civil Aviation Authority (CAA)’sresources, particularly in relation to safety and the environment.

I am now in a position to confirm that the Budget contained no proposals which would impact directlyupon CAA resources in relation to safety, the environment or other areas of the regulator’s work.

However, I would like to take this opportunity to reiterate my statement to the Committee that safety isthe top priority for Government and all the other key players in managing airspace and that the CAA, asindependent regulator, is regarded as one of the leaders in its field.

On environment, whilst the Budget did not impact CAA resources directly, it did recognise the UK’sinstrumental eVorts in negotiating a strengthened framework for the EU’s Emissions Trading Scheme (EUETS) which, from 2012, will include aviation, capping emissions from this sector while enabling cuts to bemade in the most cost-eVective way. The revised EU ETS will ensure an annual reduction in emissions upto 2020 and will support the broadening and deepening of carbon markets as part of co-ordinated actiontowards a global deal.

In conjunction with the UK’s new target to reduce total UK aviation CO2 emissions to below 2005 levelsby 2050, the UK has the toughest climate change regime in the world.

Furthermore, as I reported to the Committee, following Sir Joseph Pilling’s Strategic Review of the CAA,the Government accepts his recommendation that the CAA should be given a general statutory duty inrespect of the environment. The Government plans to bring forward suitable legislation when the legislativeprogramme allows.

I hope that this is helpful.

May 2009

Memorandum from the Chilterns Conservation Board (AIR 22)

Following the recent call for written evidence the Chilterns Conservation Board is pleased to detail itscomments below, which are submitted as evidence in connection with the above inquiry.

The Board has tried to answer as many of the questions as possible, but has focussed on those issues thatare considered to have implications for the Board or the management of the nationally designated ChilternsArea of Outstanding Natural Beauty (AONB).

The Chilterns Conservation Board is a body, set up under an Act of Parliament, that represents theinterests of all those people that live in, work in, visit and enjoy the Chilterns AONB. It is made up ofrepresentatives nominated or elected (parish council) by the following organisations:

— Bedfordshire, Buckinghamshire, Hertfordshire and Oxfordshire County Councils;

— Aylesbury Vale, Chiltern, Mid Bedfordshire, North Hertfordshire, South Bedfordshire, SouthBuckinghamshire, South Oxfordshire, Three Rivers and Wycombe District Councils;

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— Dacorum and Luton Borough Councils:

— The Bedfordshire, Buckinghamshire, Hertfordshire and Oxfordshire Parish Councils (six electedin total), and

— DEFRA (eight in total).

Summary

— The Chilterns Conservation Board is extremely concerned about the implications of the proposedgrowth in the number and frequency of flights over the Chilterns AONB. It is considered that therewould be significant detrimental impacts on the tranquillity of the AONB and the quiet enjoymentof the countryside.

— Much greater account should be taken of the current and ongoing economic conditions which haveresulted in demand being level or in decline in the short to medium term and demonstrate a patternof demand that is diVerent to that in 2003. This may well have implications for some time to come.

— The Government should take much greater account of the environmental implications of growthin the number and frequency of flights. Such implications include loss of tranquillity (particularlyin connection with protected landscapes such as National Parks and AONBs) arising fromincreased noise, the eVects of traYc congestion in the vicinity of airports and the eVects of otheremissions.

— All proposed changes to airspace should be based on thorough and up to date assessments ofcurrent demand, should consider all relevant matters even if they are diYcult to address and shouldrely on robust studies of tranquillity and all other environmental implications. The Boardconsiders that the Government should not simply respond to the airlines’ demands for increasedcapacity irrespective of the environmental consequences.

— Advice from Government to the aviation industry (CAP 725) is at present confusing andmisleading and ought to be redrafted in connection with the implications for the overflying ofprotected landscapes.

— Greater account should be taken of the implications for flying out of smaller airfields.

— All changes to airspace should be independently examined and verified by a publiclyaccountable body.

Evidence

Are the White Paper’s projections for increased passenger demand still accurate?

1. The Board considers that the projections for increased passenger demand are no longer accurate andfurther work should clearly be done now to ensure that forecasts are brought up to date to reflect the currenteconomic conditions. These conditions may apply for some time into the future (not just the short term) andshould not be dismissed as a short term issue.

2. The price of oil and the “credit crunch” have led to some major airlines significantly reducing thenumber of flights over the coming months. There is therefore no need to rush into significant changes asdemand has levelled oV and in some cases is in decline. This is particularly important when taken in thecontext of the need for a full examination and reporting of the environmental implications of air travel. Thishas been called for by a number of bodies but has yet to take place.

3. Greater consideration therefore needs to be given to diVerent scenarios rather than just a single onethat focuses on unconstrained increases in demand and the Board considers that, rather than catering forrelatively unconstrained growth, the Government should be considering only planning for managed limitedgrowth. This is because expansion will lead to greater numbers of lower overflying aircraft which willdamage the enjoyment of the special qualities of the Chilterns AONB for those people who live in and visitthis protected landscape. Airspace management does not currently give any weight to those aVected.

4. The Board considers that the inquiry also needs to take account of the implications of the carbonemissions of air travel. This is not done at present and is a serious omission that, when properly consideredwith cost implications, will almost certainly lead to a reduction in the number of passengers.

Are all the measures to provide for increased passenger demand likely to be implemented?

5. The Board considers that with falling passenger numbers and a decreasing number of flights it is mostunlikely that measures to provide for increased passenger demand will be implemented. In fact, the oppositeis probably true with contraction, rather than expansion, in the industry being the case.

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Can safety be maintained as airspace is increasingly utilised?

6. The Board does not consider that there are currently unacceptable threats to air safety in terms ofairspace use and is not aware of any significant increase in risk due to congestion that would warrantsignificant changes. In addition, with contracting services rather than increasing utilisation it is consideredto be most unlikely that it will become an issue in the future. The Board therefore considers that safety canbe maintained with current levels of airspace use, as well as if airspace is increasingly utilised, though thisis not being advocated (please see the summary detailed at the start of this document which highlights theBoard’s key concerns).

Is the current approach to planning and regulating the use of UK airspace adequate?

7. The Board does not consider that the current approach is adequate because it seems that changes arepromoted by and for the aviation industry and approved by organisations that are at arms length from anyaccountable body. Consultation on changes are inadequate (for example we only need to look at the recentNATS consultation on the TCN proposed changes to airspace to see how inadequate the consultation hasbeen) and do not reflect the procedures that are undertaken for comparative exercises in the planning spherefor example.

8. Changes should be instigated that ensure that any future consultation is thorough, transparent andaccessible to all, with proper reporting procedures leading to independent conclusions andrecommendations.

Would an Airspace Master Plan covering the period of the White Paper be beneficial?

9. The Board considers that this would be useful, but any Plan should be drafted after a thoroughexamination of the conditions that are applying at the time, and any consultation should be full and properbased on adequate and accessible information. Any conclusions should be arrived at independently of theaviation industry.

Could a piecemeal approach to individual developments necessitate additional redesigns subsequently?

10. Yes, because all matters that apply should be considered from the outset even if they are diYcult toinclude. If a problem exists then it should be addressed and not ignored because it is too diYcult (theexclusion by NATS of changes to the Bovingdon Hold as part of the recent TCN proposed changes is a verygood example).

11. The evidence base that is used for redesigns should also be up to date and should address all mattersthat are relevant (this includes impacts on things such as tranquillity and the need to have robust assessmentsincorporated).

How are the eVects and aircraft noise and emissions taken into account when changes are made to the use ofairspace?

12. The Board does not consider that adequate account is taken of the eVects of aircraft noise andemissions when changes are made. Noise is particularly intrusive in those places where background orambient noise levels are low. This applies in the more tranquil areas of the country and particularly protectedand nationally designated landscapes such as the Chilterns AONB which are by their very nature lesscongested and less densely populated.

13. Before any changes are proposed the Board considers that thorough and robust studies should beundertaken to assess tranquillity. In the Board’s experience no consideration has been given, as part ofproposed changes to airspace, to the impacts on people on the ground or their enjoyment of quiet andpeaceful countryside for example.

14. The Board also considers that much greater account should be taken of the implications of significantincreases in car use and congestion on roads local to airports. With the proximity of airports such as Lutonand Heathrow to the Chilterns AONB the eVects of increased congestion are felt in the AONB.

15. The Board also considers that the Department for Transport’s guidance to the CAA (CAP725paragraphs 45 and 46) requires redrafting in connection with the issue of the eVects of overflying of protectedlandscapes because it is being misinterpreted at present, thus resulting in proposals that would increaseoverflying of the Chilterns AONB.

16. The importance of avoiding the overflying of AONBs cannot be stressed enough and the Board alsoconsiders that there should be much more consideration of the eVects of expansion in combination with theuse of other airports (both large and small). There should also be cooperation and collaboration betweenall airports so that the full eVects of proposed changes are considered holistically.

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Who should be consulted about such changes?

17. Any consultations should be wide ranging and should include all those bodies that are likely to beaVected, including bodies that represent the countryside and protected landscapes for example. Consultingis one thing, listening to the results and doing something about it are another matter and the Board isconcerned that such consultation exercises will be seen as a “tick box” exercise on the part of the CAA andNATS for example.

18. Those populations likely to be aVected by any proposed changes should also be consulted andlistened to.

How should the balance between conflicting interests be struck?

19. The Board considers that interests of national importance (protected landscapes such as NationalParks and AONBs for example) should take precedence over the interests of the aviation industry becauseonce changes are implemented there are likely to be very few opportunities to revisit proposals and thedamage will already have been done.

20. The environmental eVects of aviation, including the impacts of noise and emissions, should featuremuch more prominently in any consideration than is the case at present.

What opportunities are there to apply new techniques and technologies to reduce wasteful flying on indirectroutes and excessive “stacking” while planes wait to land?

21. Opportunities will exist to make flying, take oV and landing procedures more eYcient, though theseshould not be introduced at the expense of the wider environment and particularly the quiet enjoyment ofprotected landscapes such as AONBs. A number of airports are in close proximity to AONBs and NationalParks and direct routes may lead to more overflying of such landscapes, therefore in some cases there willbe environmental benefits in taking an indirect route and not overflying such areas.

Could environmental benefits be gained as a result of such improvements?

22. In some instances this may arise, though, as detailed above, there may also be environmental coststhat the Board thinks would outweigh the introduction of such measures.

In relation to the redesign of UK airspace, is the allocation of the roles and responsibilities of each of theinterested parties—Department for Transport, the CAA, airport operators, NATS, etc—appropriate andclearly understood?

23. Based on the Board’s recent experience with the NATS’ TCN proposals it is quite clear that theallocation of roles and responsibilities of the interested parties are neither appropriate nor clearlyunderstood. It is understood that any redesign is proposed and approved by those within the air industrywithout any clear involvement of any directly elected or fully accountable body. This is confusing and needsto be addressed so that stakeholders have confidence in the system such that any comments that are madeare going to be taken account of fully and properly.

24. Any decisions should be independently made by a fully accountable body. In addition, the Boardconsiders that robust and up to date statistics should be used, thorough and robust studies of tranquillityshould be undertaken and the current guidance that has been issued by DfT to the CAA should also berevisited and clarified.

Are the structures of the parties appropriate for undertaking the roles that they should play?

25. The Board does not consider that bodies that are owned and operated primarily by airlines shouldbe taking decisions that have such a direct impact on their own industry. The consideration of proposalsshould be undertaken on an independent basis, but with expert input where required. The public interest isclearly not being given full and proper weight.

Do airspace management considerations delay the planning processes in relation to airport developmentproposals?

26. The Board does not consider that airspace management considerations delay planning processes inrelation to airport development proposals. In fact it has been quite clearly told that airspace managementis quite separate from development proposals and that the expansion of airports is not taken account of inairspace change proposals. The Board considers that any future expansion plans should quite clearly beinextricably linked to any airspace change proposals and vice versa.

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Ev 156 Transport Committee: Evidence

How will airspace management considerations be taken into account by the proposed new InfrastructurePlanning Commission and the relevant National Policy Statements on airport planning?

27. The Board is not sure how airspace management considerations will be taken into account by the IPCor National Policy Statements, but it is clear that any proposals should be subject to full and properconsultation with all those that have an interest in the proposals, including relevant stakeholder groups andaVected local populations.

What could be the implications for smaller airfields, recreational flying and helicopters of changes to airspacemanagement to enable safe and eYcient increases in capacity at the UK’s major airports?

28. The Board considers that, rather than catering for relatively unconstrained growth, the Governmentshould be considering only planning for managed limited growth. The question ought to be considered inthe light of the current and ongoing economic climate, which is likely to have significant implications in themedium to long term.

29. The Board also considers that the use of smaller airfields, recreational flying and use of helicoptershave wider implications arising from intrusive noise caused by lower flying aircraft that ought to be broughtunder more control than is the case at present. Many smaller airfields are within or in close proximity toprotected landscapes such as the Chilterns AONB and their use often has detrimental impacts on thetranquillity of the protected landscape.

How should an appropriate balance between conflicting priorities be determined?

30. The Board considers that based on a thorough assessment of the implications of any proposals thatnational priorities should have an overriding importance (and includes nationally protected landscapes suchas AONBs and National Parks in this) over the interests of a single industry, which is working for profit andthe benefit of shareholders rather than for the benefit of the public.

Will it be possible to recruit and train staV in order that airspace changes can be implemented in parallel withadditional airport capacity?

31. The Board does not consider that this issue needs to be examined in any great detail unless it is quiteclear that there is robust and up to date evidence that shows that additional airport capacity is required.Should extra staV be required the Board considers that if the right incentives are in place then adequatenumbers of staV could be recruited.

32. However, based on the location of many airports in the south east of England, there are likely to behousing aVordability issues for new staV that may be recruited. This may then result in greater commutingdistances and increased congestion in the vicinity of airports. This would aVect a number of AONBs andparticularly the Chilterns AONB which is close to both Heathrow and Luton airports.

Who should fund airspace changes?

33. The Board considers that any airspace changes should be administered and funded by Governmentin order to ensure that any proposed changes are independently verified.

Is there likely to be enough funding to undertake the redesign required to bring about the necessary additionalairspace capacity?

34. Once again the Board considers that this question is wrongly based on the premise that additionalairspace capacity is needed. Up to date studies should be undertaken to assess what the likely level ofdemand will be based on the current economic climate rather than proposals being based on informationthat is now at least four years out of date. If there is no longer a need for additional airspace capacity thenthe funding will not be required for redesign work.

October 2008

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Memorandum from the International Air Transport Association (AIR 23)

Executive Summary

IATA recognises the importance of the UK Government’s statement in the White Paper for “a structuredprogramme for the redesign of UK airspace that would help protect safety standards, relieve currentconstraints, take account of environmental impacts and accommodate the forecast increase in air transportmovements where additional capacity was supported”. IATA recognises the importance of these objectiveswhich could be realised as follows:

— planning for airspace capacity is essential if delays and congestion is to be avoided; and

— a more strategic and top down approach is required to airspace planning and design. This couldbe realised by each actor having clearer accountabilities:

— DfT responsible for a National Policy Statement on aviation including the provision ofairspace resources to meet demand,

— CAA to own a high level airspace strategy together with a Master Plan to meet futurecapacity needs,

— NATS responsible for detailed airspace design within the framework defined above, and

— Operators to meet performance standards in order to access airspace.

— assuring the independence of an airspace regulator in order to meet the needs of all users:commercial, military and general aviation. Coordination with other agencies responsible for theprovision of strategic aviation infrastructure is recommended;

— taking account of the obligations of the Member States in the Single European Sky, ensure anetwork based approach for the design, planning and management of Europe’s airspace includingthe development and implementation of new concepts of operation, the associated technologicalsystems and the relevant operational procedures; and

— adequate specialist resources are required to plan airspace in a timely and cost eVective manner.Adequate financing, funded from public sources, will be required to plan airspace in parallel withairport developments.

1. What changes to the management of airspace could be required as a result of the additional airport capacityoutlined in the 2003 White Paper? Are the White Paper’s projections for increased passenger demand stillaccurate? Are all the measures to provide for increased passenger demand likely to be implemented?

1.1 In general IATA believes that the figures for passenger demand remain accurate although there maybe some small reductions as a result of falling demand associated with the high cost of fuel and the downturnin many national economies.

With respect to the planning for air traYc management movements as distinct from passenger demand,IATA accepts that the current scenario is for a 75% rise in traYc in 2020 compared with the 2004 baseline.

2. Can safety be maintained as airspace is increasingly utilised? Is there a suitable interface between militaryand civilian arrangements for air traYc control?

2.1 Yes, provided a Safety Management System (SMS) is always applied to the design and managementof airspace changes. The SMS process is designed to provide the evidence to an independent regulator—theCAA’s Safety Regulation Group—that safety levels are maintained if not increased.

2.2 The UK is a good example of a joint and integrated approach between civil and military entities toairspace design, planning and management.

3. Is the current approach to planning and regulating the use of UK airspace adequate? Would an AirspaceMaster Plan covering the period of the White Paper be beneficial? Could a piecemeal approach to individualdevelopments necessitate additional redesigns subsequently?

3.1 The current process for planning and regulating UK airspace is based on the Airspace Change Processpublished in CAP 725, “CAA Guidance on the Application of the Airspace Change Process”. Theseguidelines were revised in 2007. Whilst these processes have proved suYcient in the past, IATA has somedoubts as to whether the current guidance or procedures are the most eYcient or eVective in terms ofsatisfying the future and timely need for a strategic resource—airspace. This is particularly important in thecontext of a national infrastructure requirement for additional airport and runways capacity as outlined inthe 2003 White Paper.

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3.2 IATA believes that a National Airspace Master Plan would be highly beneficial providing such adocument is recognized as part of a National Policy Framework. Such an approach would require politicalendorsement by the relevant authorities and as a consequence influence subsequent decisions by the CAAregarding more detailed implementation decisions. The benefits of such an approach would be:

(a) A more strategic and top down approach to airspace planning.

(b) Timely decision-making regarding the provision of suYcient airspace resources to meet thepredicted demand.

(c) Increased certainty for the industry and will facilitate the necessary financial and investmentplanning.

4. How are the eVects and aircraft noise and emissions taken into account when changes are made to the useof airspace? Who should be consulted about such changes? How should the balance between conflicting interestsbe struck?

4.1 The eVects of noise and emissions can be analysed, modeled and predicted using the processesoutlined in the CAA’s Airspace Change Process

4.2 IATA is of the opinion that:

— around all major airports there should be full public consultation on proposed airspace changesbut these should be timely and eYcient and should not be allowed to unduly extend the planningprocess. The Government needs to establish a clear environmental policy which recognizes thetrade-oV between noise and emissions and at diVerent levels and parts of the operation;

— outside of controlled airspace there should be consultation with defense and general aviation usersin order to assure a balanced and fair approach between all airspace users; and

— above 7,000 feet, there should be a general presumption that all airspace users suitably equippedto a certain standard and under the guidance of an ATC authority, can operate safely without beingsubject to the full rigors of the Airspace Change Process provided that a National Policy Statementhas been endorsed at the political level and the airspace change has been incorporated within theNational Airspace Master Plan.

5. How does the management of airspace in the rest of Europe aVect flights into the UK? Is there an opportunityto integrate our plans for changes to airspace management more eVectively with those of other Europeancountries?

5.1 Airspace can only be eYciently managed from a network perspective that takes account of allmovements particularly in the congested parts of SE England and the interface with both the oceanic andcontinental flow. The very dense airspace between the four major hubs of London, Amsterdam, Frankfurtand Paris is particularly challenging and requires a coherent approach to airspace design between the six airnavigation services providers involved. Further the continuously growing demand from both civil andmilitary users is such that new organizational arrangements are required to manage this airspace.

5.2 IATA strongly believes it is no longer possible to design national airspace in isolation without takingfull account of adjacent international airspace particularly from an operational, safety and environmentalperspective. The European Commission has promoted the importance of rationalizing Europe’s Air TraYcManagement System in the Single European Sky project and has proposed two important measures toimprove the eYciency of air navigation service:

(a) Functional Airspace Blocks (FAB) to improve traYc flows. The FAB Europe Central project ofthe 6 States UFrance, Germany, Switzerland, Netherlands, Belgium and Luxembourg and with theUK as an associate partnerT if of major strategic importance for reducing delays and flightineYciencies in Europe’s most complex airspace.

(b) A centralized Network Manager Function to ensure consistency in airspace design and airspacemanagement across national boundaries together with various airspace programmes promoted bythe Eurocontrol Organisation.

5.3 IATA recognizes the importance of the SES project to overcome the following issues which exist atthe European or Network level and require national authorities such as the CAA to coordinate its planningacross national boundaries:

— Flight ineYciencies accounted for detours of 468Mkm in 2007 resulting in between 1.6 and2.5Beuro unnecessary fuel costs for the airlines. If related costs such as aircraft utilization,maintenance and staV costs are included then the total cost related to flight ineYciency is estimatedat between 4 to 7Beuros per year.

— The environmental impact of such ATM detours together with ineYciencies on the ground resultin avoidable emissions of 16 million tons of CO2 per year.

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— Air TraYc Flow Management delays were 21.7 million minutes in 2007 resulting in an additional1.3Beuros costs for airlines.

— The cost of fragmentation amounts to an additional and unnecessary cost of one billion eurosper year.

(Source: Eurocontrol’s Performance Review Commission PRR 2007 May 2008.)

6. What opportunities are there to apply new techniques and technologies to reduce wasteful flying on indirectroutes and excessive ‘stacking’ while planes wait to land? How can the potential of any such opportunities bestbe realised? Could environmental benefits be gained as a result of such improvements?

6.1 The SESAR (Single European Sky ATM Research) project has identified the need for a new paradigmin Air TraYc Management in order to meet future capacity requirements. The major elements in the SESARMaster Plan have been identified as follows:

— developing advanced concepts of operation (eg trajectory based operations) which increase safety,capacity and flight eYciency;

— moving away from fixed airspace and route structures to dynamic and real time management ofairspace using integrated civil/military arrangements promoted by the FAB concept;

— managing Europe’s network more eVectively by a centralized Network Manager;

— more automation in conflict detection and resolution supporting both pilots and controllers; and

— queue management tools for both the departure and arrival sequence of flights.

6.2 SESAR has quantified the environmental improvements from new concepts of operation, newprocedures and technologies. These amount to 17 million tons of fuel savings and 50 millions tons of CO2

up to 2020. Fuel savings for airlines amount to 8 billion euros at fuel price of 0.54 US dollars per kg.

(Source: SESAR Consortium, D5 SESAR Master Plan 2008.)

7. In relation to the redesign of UK airspace, is the allocation of the roles and responsibilities of each of theinterested parties-Department for Transport, the CAA, airport operators, NATS, etc-appropriate and clearlyunderstood? Are the structures of the parties appropriate for undertaking the roles that they should play?

7.1 Whilst the current arrangements have served the needs of all aviation users, there will be additionalbenefits if a top down approach complements the current arrangements and is fully aligned or integrated,as required, into European developments such as the Single European Sky and the SESAR project.

7.2 IATA is of the view that the current arrangements could be streamlined so that each actor has clearaccountabilities as follows:

— The DfT should be responsible for a National Policy Statement on aviation transport whose scopeincludes the airspace resources deemed necessary to satisfy the medium to long-term predicteddemand.

— The UK CAA should own a high level national airspace strategy together with a Master Plan tomeet capacity requirements and the needs of all airspace users.

— NATS should continue to be responsible for detailed airspace design but within the frameworkoutlined above. Fast tracking of airspace changes in the national interest should be permitted andwithout excessive consultation processes.

— All aircraft operating in controlled airspace and in defined route structures- where needed in verycongested airspace, need to have appropriate levels of system equipage and aircraft performancecapability in order access airspace and maintain safety levels.

8. Do airspace management considerations delay the planning processes in relation to airport developmentproposals? How will airspace management considerations be taken into account by the proposed newInfrastructure Planning Commission and the relevant National Policy Statements on airport planning?

8.1 IATA does not support the proposed new Infrastructure Planning Commission having any executivefunction in approving airspace changes. These powers should remain with the CAA and should not beincorporated into planning law. However the provision of a National Policy Statement for airportinfrastructure should recognize the need for airspace as a strategic resource and there may be merits withthe CAA assisting any authority with a clear understanding of the airspace implications for enhancingairport capacity.

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9. What could be the implications for smaller airfields, recreational flying and helicopters of changes toairspace management to enable safe and eYcient increases in capacity at the UK’s major airports? How shouldan appropriate balance between conflicting priorities be determined?

9.1 In general, IATA believes that all airspace users need to be accommodated in the network and thatan independent regulator should provide assurance of fair allocation, non-discrimination and clear rules toaccess and operate in the network. This may entail rigorous performance standards for:

(a) the equipment to be fitted on board aircraft;

(b) compliance to validated procedures of operation by all operators; and

(c) the service level provided by the Air Navigation Service Provider.

These requirements are necessary to assure the highest safety levels at major airports and may imply thatcertain categories of users are excluded from certain airspace because of non-compliance with the relevantrules. Furthermore safety rules must be respected at all times and take precedence over all other rules suchas environmental policies or constraints such as noise or emissions

10. Will it be possible to recruit and train staV in order that airspace changes can be implemented in parallelwith additional airport capacity?

10.1 IATA believes that adequate specialist resources should be secured to plan airspace in a timely andcost eVective manner. NATS has responsibility under its License to provide suYcient capacity in the ATMsystem and is already engaged in the detailed design of the UK’s National airspace to meet this requirement.However a more proactive and strategic approach may entail additional resources particularly if all theairport master plans were to be delivered in full. Airport capacity together with an examination of the eVectson the environment need to be considered as part of the policy decisions on airport expansion.

11. Who should fund airspace changes? Is there likely to be enough funding to undertake the redesign requiredto bring about the necessary additional airspace capacity?

11.1 The development of airports takes place in a national economic framework that providesopportunities for economic growth, jobs, tourism and regional development. Similarly the need for airspaceis linked to airport developments and airspace, as a national asset, must be used eYciently in the interestsof all airspace users. Consequently IATA believes that there is a compelling case to ensure that adequatepublic resources are allocated by the DfT to fund the provision of airspace needed to satisfy the nationalneed as defined in the National Policy Statement.

October 2008

Memorandum from the Society of British Aerospace Companies (AIR 24)

Introduction

1.1 SBAC is the UK’s national trade association representing companies supplying civil air transport,aerospace defence, homeland security and space markets. SBAC encompasses the British Airports Groupand UKspace. Together with its regional partners, SBAC represents over 2,600 companies across the UKsupply chain, assisting them in developing new business globally, facilitating innovation and competitivenessand providing regulatory services in technical standards and accreditation.

1.2 Aerospace is one of the few successful and globally competitive manufacturing sectors of the UKeconomy. Aerospace primes and their supply chain companies compete on an international basis. Thecompetitiveness of the UK supply chain aVects the competitiveness of the whole industry.

1.3 The UK aerospace industry recognises its environmental responsibilities and is investing considerablefinancial resources in an ongoing programme of performance improvements. It is firmly committed tominimising its environmental impact and the sector is making significant contributions through research,technological progress and operational measures. As such we are a leading member of the UK SustainableAviation initiative, which includes airlines, airports, manufacturers and the UK’s leading air navigationservices provider (ANSP).

1.4 We are pleased to have the opportunity to comment on the changes proposed to UK airspace throughthis consultation. Where appropriate, we have commented on specific questions that relate to SBAC’sactivities and/or the interests of our members.

1.5 How are the eVects of aircraft noise and emissions taken into account when changes are made to theuse of airspace? Who should be consulted about such changes? How should the balance between conflictinginterests be struck?

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1.6 Aircraft engines produce a range of diVerent emissions. Some of these aVect local air quality whilstothers have global impacts, contributing to climate change. There is significant scientific uncertaintyregarding the eVects of many aviation emissions, however, the main contributors to climate change arewidely accepted to be carbon dioxide (CO2), oxides of nitrogen (NOx) and water vapour (H2O), which incertain conditions can combine with the H2O already in the atmosphere to form condensation trails andcirrus clouds.

1.7 In 2001, the Advisory Council for Aeronautical Research in Europe (ACARE) proposed challengingenvironmental targets for the aviation industry including a 50% reduction in CO2 emissions and an 80%reduction in NOx emissions for aircraft entering into service from 2020, relative to their year-2000counterparts. As the amount of CO2 produced depends directly on the amount of fuel burned, to reduce CO2

emissions the amount of fuel that must be burned to carry a given payload over a given range needs to bereduced. Hence, improvements in airframes, engines and air traYc management all have a role to play inreducing CO2 emissions.

1.8 Changes to UK airspace are made through the process set out in the CAA Directorate of AirspacePolicy (DAP) Airspace Charter. This can require ANSPs to conduct consultation exercises with bothairspace users and environmental stakeholders beneath proposed changes. The environmental consultationis normally only carried out with respect to airspace changes below 7,000 feet but there are exceptions forairspace changes over Areas of Outstanding Natural Beauty (AONBs) and National Parks.

1.9 We believe that the current system of consultation on proposed changes to airspace is alreadycomprehensive and allows for extensive stakeholder engagement, including government (central/regionaland local), local communities, businesses, environmental groups and the aviation industry.

1.10 NATS has committed to reducing CO2 emissions by 10% per flight by 2020 relative to a 2006baseline. ANSPs such as NATS continually evaluate their route networks to assess where there is potentialneed for redesign in order to maintain capacity and how certain routes could change to improve theireYciency and possibly reduce their lengths. However, there are trade-oVs between emissions and noiseexposure. For example, within the proposed changes to airspace being considered under the TerminalControl North consultation, routes below 4000 feet have generally been positioned to avoid flying oversizeable population centres. Between 4000ft and 7000ft, an attempt has been made to balance the demandsof mitigating noise and reducing fuel burn and emissions. Above 7,000 feet increasing fuel eYciency andreducing emissions has taken priority.

1.11 Changes to existing airspace inevitably mean making diYcult and complex decisions which recognisethe need to take into account the aims of reducing delay and mitigating the environmental eVects, whilstensuring safety. Any changes made to existing airspace will attempt to achieve a balance between these oftencompeting demands.

1.12 How does the management of airspace in the rest of Europe aVect flights into the UK? Is there anopportunity to integrate our plans for changes to airspace management more eVectively with those of otherEuropean countries?

1.13 It is predicted that by 2020 there will be 17 million flights in the European airspace per year. Toaccommodate this volume of traYc, a three-fold increase in capacity from 2000 levels is required. Thereforedespite current initiatives underway and already producing good results, significant further work is requiredin ATM and operations to avoid ineYciencies and delays. In the long term, the Single European SkyResearch Programme (SESAR) is expected to deliver substantial improvements for the European airspace.However, eVective measures that can be delivered in the short term are required. Work is currently ongoingat the European level through the DMEAN and TMA2010! projects in this regard.

1.14 DMEAN is a five-year European Framework Programme led by EUROCONTROL that aims todeliver an additional 10% capacity to the 10-15% believed to be delivered through current initiatives. Oneof the priorities of the DMEAN Programme is to establish an improved interface between airports and theEuropean ATM system. This will be undertaken through the ‘Airport Operations within the Network’component of the programme. Collaborative Decision Making (CDM) is the principle vehicle for improvingthe interface. The idea is to extend CDM, which is already utilised by some airports and ANSPs, to manymore airports throughout Europe to provide more accurate data for inbound flights, new information oncapacity issues at other airports or in other airspace, and improved knowledge of weather-relateddisruptions. This new and improved knowledge will assist decision making and allow airports to have a moredirect role in strategic planning.

1.15 As Terminal Manoeuvring Area airspace becomes increasingly busy and progressively morecomplex, and although some initiatives such as P-RNAV and Continuous Descent Approaches (CDAs) arebringing benefits today, more is needed, especially for high-density operations. TMA 2010! is acollaborative programme whose partners include EUROCONTROL, QinetiQ and NATS. Althoughengaged in a wide range of activities in relation to TMA operational improvements, the main focus for theTMA2010! Project is the development of the requirements and specifications of new arrival managementsystem support tools. Phase 1 of the project aims to deliver quick win benefits to airspace users by 2010.Phase 2 aims to deliver a package of tools and procedures for implementation by 2015. Phase 3 is lookingat enhanced procedures and tools beyond 2015 that align with the SESAR programme.

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Ev 162 Transport Committee: Evidence

1.16 The SESAR programme is a ƒ2.1 billion European Union ATM modernisation programmedesigned to integrate and extend the eVorts of past and current ATM initiatives so that their benefits canbe fully realised. The programme will bring together the technological, economic and regulatory aspects ofthe ATM issue and use the Single European Sky legislation (introduced by the European Commission in2004 to unlock viable growth in the European air traYc system) to synchronise the actions of diVerentstakeholders and concentrate resources. SESAR has many ambitious objectives to achieve by 2020 relativeto a 2005 baseline including:

— reduce environmental impact (CO2 emissions) by 10% per flight;

— increase the capacity of the European sky by 73%;

— reduce ATM costs by 50%; and

— increase safety by a factor of three.

1.17 However, ultimately the ATM target concept developed through SESAR will go beyond thesetargets, enabling a three-fold increase in capacity and a 10-fold increase in safety within Europe.

1.18 What opportunities are there to apply new techniques and technologies to reduce wasteful flying onindirect routes and excessive ‘stacking’ while planes wait to land? How can the potential of any suchopportunities best be realised? Could environmental benefits be gained as a result of such improvements?

1.19 The high engine power settings required for take-oV and climb means that a significant proportionof fuel is burned in this phase of flight, particularly for short haul flights. Current practice sees aircraftclimbing to cruise altitude in a series of steps separated by periods of level flight. This keeps departing traYcseparated from those aircraft arriving and transiting to other airports but is not the most eYcient way foran aircraft to reach cruise. Climbing continuously from the ground up to cruise altitude eliminates the needfor additional thrust in the segments of level flight and also means aircraft spend longer at flight levels closerto their optimal altitude which leads to a reduction in fuel burn and emissions.

1.20 Current airspace design means that this concept, known as “Continuous Climb Departure” (CCD),is not currently in use in the UK. However, programmes such as the US/EU Atlantic InteroperabilityInitiative to Reduce Emissions (AIRE) are working to evaluate its feasibility and impacts. Before thisdeparture technique can be implemented the eVects of such a change need to be carefully considered as CCDsmay lead to other unwelcome impacts such as more ineYcient overall routings and increased levels of noise.

1.21 Operating altitude, speed and route can all significantly aVect fuel eYciency, emissions and noiseduring cruise. When an aircraft is not flying at its optimal altitude, fuel consumption and emissions areincreased. However, determining the best altitude at which to fly is not straightforward, as optimal altitudevaries with aircraft type and throughout the flight. As fuel is burned, aircraft weight is reduced and theaircraft needs to climb higher in order to maintain its optimum cruise eYciency. In addition, environmentalconditions such as favourable wind speeds and directions may mean that it is better to fly at higher or loweraltitudes at certain points throughout the flight.

1.22 Every aircraft is designed to operate at a set of specified conditions, known as its “design point”.This includes a particular cruise speed (Mach number). Although aircraft can safely operate at conditionswithin an envelope around their design point (known as the operating envelope), their performance at theseoV-design conditions is not optimal and will incur penalties such as increased fuel consumption. As there isa direct relationship between aircraft speed and fuel burn, reducing cruise speed whilst staying within theaircraft’s operating envelope, can be an eVective way to reduce fuel burn and emissions.

1.23 Designing and utilising shorter, more direct routes can lead to significant reductions in fuel burnand emissions. This includes using route profiles with optimal ascent and descent approaches and increasingthe height at which aircraft are held before landing, as this keeps the aircraft higher, where the air is lessdense, thereby resulting in less drag and hence fuel burn.

1.24 EVorts underway to optimise height, speed and route profiles include those made as part of theCRISTAL In-trail Procedure (ITP), which allows an aircraft to perform altitude changes more easily duringcruise (thereby reducing fuel burn and emissions). These have recently been trialed by Airbus andScandinavian Airlines (SAS). The demonstration took place in Iceland in March 2008 using Airbus’ ownA340 test aircraft and an SAS A330. During the flight test, the A340 aircraft performed a number of altitudechanges using a new navigation system fitted in the aircraft. The system, which is based on ADS-B(Automatic Dependant Surveillance—Broadcast) and uses new air-to-ground and air-to-air surveillancetechnology to transmit information, enabled the pilot to receive all the flight identification and positioninginformation about the surrounding aircraft on his navigational flight display. This technology is currentlybeing certified for use by Airbus.

1.25 This successful trial represents a significant step forward in the flexibility of oceanic operations.Currently, the lack of radar systems limits the changes in cruise altitude an aircraft can make within theoceanic airspace. However, with this new technology, the flight crew will be able to provide the air traYccontroller with precise information about the aircraft’s position relative to other aircraft. Air TraYcControllers can then use this information to instruct air crew to change altitudes while maintaining reducedseparations. This creates more climbing opportunities for the aircraft.

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1.26 With regard to arrivals, an eYcient approach to landing is one that does not require any additionalenergy input (eg no level sections of flight or holding periods requiring engine thrust). This can be achievedby managing the aircraft’s momentum from Top of Descent (TOD), en-route or stack altitude such that itsvertical and lateral speed onto the glide slope are optimised for its type to ensure a safe and fuel eYcientlanding.

1.27 As a result of inherent airspace restrictions, aircraft have traditionally descended towards theirdestination in a series of steps. However, from both a fuel burn and emissions and a noise perspective, thisapproach is not ideal. With a Continuous Descent Approach (CDA), an aircraft descends towards an airportin a gradual, continuous approach with the engine power cut back. By flying higher for longer andeliminating the need for the extra thrust required for the periods of level flight between steps of descent,CDAs result in average reduced fuel burn and emissions of 100 kg of fuel and 315 kg of CO2 per flight,compared to a conventional approach. Deferring the start of descent also means less noise exposure forcommunities under the early descent phase of the flight path.

1.28 Currently, CDAs are agreed by the air traYc controllers and pilots on a flight-by-flight basis,according to weather and traYc conditions. Their use in the UK is well-established; they have been usedextensively in the UK for certain airports such as London Heathrow for several years with no impact on theairport’s capacity. However, CDA utilisation is often limited by ATM resource, airspace capability or pilotuptake. These approaches need dedicated control assistance throughout the approach which is very timeconsuming and not always possible during busy periods. Advanced, automated CDAs are however nowbeing tested. With this new procedure the aircraft’s flight management system automatically receivesinstructions from the on-ground ATC system on how to descend such that the most eYcient descentapproach is used.

1.29 Steeper approaches, which aim to keep the aircraft as high as possible for as long as possible, areprimarily flown for noise abatement reasons, however they also oVer emissions savings. A notable user ofsuch approaches is London City where a glide path angle of 5.5 degrees (compared to three degrees for astandard CDA) is routinely flown. Low power low drag (LPLD) approaches are another example ofenvironmentally friendly approaches. They use low engine power low drag profiles to reduce fuel burn andnoise. With these approaches, the aircraft keep the most aerodynamically “clean” configuration for as longas possible subject to given operating conditions (weather, air traYc conditions, etc), thereby minimisingdrag and hence thrust requirements and fuel burn. This means that the deployment of equipment like theaircraft’s flaps and landing gear is delayed as much as possible. These approaches are in use at some UKand EU airports. However, it is becoming increasingly recognised that the optimum approach procedure isa combination of LPLD and CDA, as this allows for eVective speed and energy management while alsoreducing noise impact.

1.30 EUROCONTROL estimates that if CDAs became standard throughout Europe around 945,000tonnes of CO2 emissions would be saved each year. However, unfortunately CDAs cannot be used at allEuropean airports at all times. At busy airports, descending aircraft are not allowed to fly freely down theiroptimum descent paths. This is because the controller needs to have the flexibility to intervene as requiredto appropriately space the descending aircraft to accommodate for changes in conditions (traYc, weatheretc.) and fulfil safety requirements for aircraft in terms of separation for aircraft wake vortices.

1.31 A number of projects that attempt to preserve flexibility, whilst ensuring that optimal approachesare used wherever feasible, are underway throughout Europe. These make use of a number of advanced pilotand controller tools including P-RNAV, which, with an additional vertical navigation capability, VNAV, canbe used to very accurately define an arrival route; and a suite of tactical control tools which can help toprovide more certainty in the Required Time of Arrival (RTA) of aircraft on approach, relative to each other.

October 2008

Memorandum from the Aviation Environment Federation (AIR 25)

Who we are

The Aviation Environment Federation (AEF) is the principal UK non-profit making environmentalassociation concerned with the environmental eVects of aviation. It promotes a sustainable future foraviation which fully recognises, and takes account of, all its environmental and amenity eVects. These rangefrom aircraft noise issues associated with small airstrips or helipads, to the contribution of airline emissionsto climate change.

The AEF was established in 1975 because of growing concerns about noise from private aircraft. Thisremains an important part of AEF’s work, but in recent years increasing attention has been focussed on theimpacts of commercial aviation. AEF is a membership organisation which provides an advice andinformation to its members. We have over 120 aYliated members comprising community and environmentalgroups, local authorities, parish councils, businesses and consultancies and individuals.

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The document below sets out our key responses to the call for evidence, and then more detailed responsesto the questions contained in the call for evidence. Appendix A contains a numbered list of the questionsAEF has responded to.

Key Recommendations

— Independent research is required to revise growth forecasts to the point where a suYciently robustAirspace Master Plan would be feasible.

— An Airspace Master Plan should contain comprehensive mapping of airspace blocks and projectedtraYc flows, assessment and projection of current and future emissions and strategies for reducingthese, more clarity on the issue of rural/urban routing, strategic guidance on the preservation ofAreas of Outstanding Natural Beauty and National Parks, and projections for the maximumeYciencies that can be achieved in case of increased capacity/usage.

— Airspace change proposals should be closely tied to land use planning, managing any planningrestrictions or environmental impacts through thorough local consideration and the eVectivecommunication of alternative measures. Airspace management it must be brought forward in theplanning process, if necessary, with outline permission being gained before further planningconsideration is undertaken.

— The eVects of aircraft noise and emissions on local populations are not given equal considerationwith capacity. There should be accepted thresholds for environmental impacts which, if exceeded,would invalidate Airspace Change Proposals (ACPs).

Detailed Responses

1. AEF does not have the expertise to comment on all the details of airspace management, however, weare concerned with its environmental implications. As an overall remark we believe this consultation ispremature, as growth levels and the structure of the industry are in flux. Revised forecasts are required toensure no non-essential capacity is built, thus reducing pressure on airspace operators to increase capacityto unsustainable levels. We have asked the DfT to provide revised forecasts before any capacity decisionsare made.

2. The extent to which safety may be compromised depends partially on the congestion of routes. Careshould be taken to ensure that safety standards do not lapse to increase capacity, and that penalties againstlevel-busts etc are severe. While our members understand the focus on safety, decisions on the location ofnew capacity will influence the size and shape of Public Safety Zones, and thus planning decisions. Moredetailed strategic guidance, formulated with comprehensive consultation and independent research isneeded over the viability and impacts of rural routing being used in preference over urban areas.

3. The planning and regulation of UK airspace requires long-term strategic support. Providingcomprehensive, independent evidence is used for its construction, an Airspace Master Plan covering theperiod of the White Paper would be beneficial. Piecemeal approaches to individual developments and anysubsequent redesigns should be considered under the strategic framework of the Airspace Master Plan,which should be non-site-specific, and used alongside the Air Transport White Paper 2003. Without this, itwill be diYcult to determine if the White Paper projections can be safely met.

AEF envisages any airspace Master Plan would contain comprehensive mapping of airspace blocks andprojected traYc flows, assessment and projection of current and future emissions and strategies for reducingthese, more clarity on the issue of rural/urban routing, strategic guidance on the preservation of Areas ofOutstanding Natural Beauty and National Parks, and projections for the maximum eYciencies that can beachieved in case of increased capacity/usage. Airspace changes should have closer links to land-use planning.Where increased airport capacity is proposed, airspace should be considered in parallel, with mappingavailable to consultees, but no formal planning status.

4. The eVects of aircraft noise and emissions on local populations are not given equal consideration withcapacity. The Environment Agency should be a key consultee. There should be accepted thresholds forenvironmental impacts which, if exceeded, would invalidate Airspace Change Proposals (ACPs). The degreeof environmental information provided by National Air TraYc Services (NATS) has improved, yet stillremains inadequate overall. ACPs consistently undervalue the importance of reductions in noise andemissions. Research into degrees of intrusiveness of air routing is not yet robust enough for the formulationof proper policy guidance, resulting in a shifting of environmental impacts, rather than solving them. Moresophisticated guidance is required from the DfT, and a revision of current guidelines for airspace planning.At present, the focus on concentration and minimising the number of people aVected by aircraft noise, failsto recognise emerging environmental policy, not least the protection of tranquil areas.

5. Better integration with EU airspace is necessary if coastal stacking is to be an option. A singleintegrated EU airspace block would increase eYciency, for example by allowing direct routing betweenstates, and we urge the UK Government to continue to push for an agreement on the Single European Sky.

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6. If the Terminal Control North consultation is a good indicator of technology being used to achieveenvironmental benefits, then it is clear that such benefits are minimal when compared with the environmentalimpacts of the capacity growth envisaged, for the South East in particular. Greater emphasis should beplaced on maintaining environmental standards, which should not be considered as subsidiary to capacityconstraints. It is disappointing that the increasing use of CDA and PR-Nav technological advances havenot led to parallel environmental gains. Many of the initiatives presented served to move the environmentalimpacts rather than resolve them, with the resultant capacity increases leading to an overall increase inemissions- a highly unsustainable position if the aviation industry is to counter its climate change costs.

7. NATS, as a source of expert advice and data need to enhance their role in the planning process. NATSconcerns about capacity limitations should take precedence over externally set growth targets. In order forthe CAA to strengthen its reviewing process of actual operations, it must demonstrate its possession of theresources to enforce Airspace Change Sponsors to follow CAP725. Areas of responsibility should be clearlydelineated. Better definition of these roles would lead to increased transparency and democraticaccountability. The DfT should provide strategic objectives for Air Space Managers.

8. Under current arrangements, airspace management is given no consideration in airport developmentproposals; it must be brought forward in the planning process, if necessary, with outline permission beinggained before further planning consideration is undertaken. This is why new National Policy Statements onairport planning should contain a fully comprehensive Airspace Master Plan. CAA/NATS role in theplanning process should be strengthened as suggested above. Where consultations are carried out onexpansion, basic Airspace Change mapping should be included, to increase public awareness of areasaVected.

This is a fundamental flaw with the present approach. For example, the Government consulted widely onthe airport expansion proposals presented in the 2003 ATWP, but airspace considerations were confined toa few paragraphs stating simply that: “The Government will now look to the CAA to make early progressin bringing forward a structured programme for the redesign of UK airspace, with a view to the phasedimplementation of changes to eliminate constraints and permit the integration of the forecast increases inaircraft movements, including traYc using the additional runways proposed in this White Paper” Thosebeing consulted now by NATS, were not necessarily those impacted or consulted by the airport expansionoptions in the ATWP. This has confined the NATS consultation to questions of “where” rather than allowingcommunities to voice concerns about the general volume of traYc.

9. With increased commercial capacity, viable Class G airspace for recreational and private flying coulddecrease. The erosion of uncontrolled airspace could bring recreational aircraft lower, and/or create moreintensive corridors as aircraft navigate around controlled areas. This would create problems with increasednoise and emissions in these areas. General Aviation has its own environmental considerations, which willnot be mitigated by constraining its operations.

10. Personnel issues should be resolved by greater collaboration and training initiatives between the CAAand NATS. For greater integration with land use planning issues, collaboration with Local Authorityplanners will be necessary.

11. Those benefiting from additional airspace capacity should fund changes. If carriers want greatercapacity, they should meet the costs associated with the investment in safe routes- the same applies toairports looking to attract more carriers. Central government backing should be made available to ensuresafety standards are maintained, conditional upon consideration of environmental mitigation measures, andmaximizing environmental benefits.

APPENDIX A

1. What changes to the management of airspace could be required as a result of the additional airportcapacity outlined in the 2003 White Paper? Are the White Paper’s projections for increased passengerdemand still accurate? Are all the measures to provide for increased passenger demand likely to beimplemented?

2. Can safety be maintained as airspace is increasingly utilised?

3. Is the current approach to planning and regulating the use of UK airspace adequate? Would anAirspace Master Plan covering the period of the White Paper be beneficial? Could a piecemeal approach toindividual developments necessitate additional redesigns subsequently?

4. How are the eVects and aircraft noise and emissions taken into account when changes are made to theuse of airspace? Who should be consulted about such changes? How should the balance between conflictinginterests be struck?

5. How does the management of airspace in the rest of Europe aVect flights into the UK? Is there anopportunity to integrate our plans for changes to airspace management more eVectively with those of otherEuropean countries?

6. What opportunities are there to apply new techniques and technologies to reduce wasteful flying onindirect routes and excessive ‘stacking’ while planes wait to land? How can the potential of any suchopportunities best be realised? Could environmental benefits be gained as a result of such improvements?

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Ev 166 Transport Committee: Evidence

7. In relation to the redesign of UK airspace, is the allocation of the roles and responsibilities of each ofthe interested parties—Department for Transport, the CAA, airport operators, NATS, etc—appropriateand clearly understood? Are the structures of the parties appropriate for undertaking the roles that theyshould play?

8. Do airspace management considerations delay the planning processes in relation to airportdevelopment proposals? How will airspace management considerations be taken into account by theproposed new Infrastructure Planning Commission and the relevant National Policy Statements on airportplanning?

9. What could be the implications for smaller airfields, recreational flying and helicopters of changes toairspace management to enable safe and eYcient increases in capacity at the UK’s major airports? Howshould an appropriate balance between conflicting priorities be determined?

10. Will it be possible to recruit and train staV in order that airspace changes can be implemented inparallel with additional airport capacity?

11. Who should fund airspace changes? Is there likely to be enough funding to undertake the redesignrequired to bring about the necessary additional airspace capacity?

October 2008

Supplementary memorandum from the Aviation Environment Federation (AEF) (AIR 25A)

In relation to the Oral Evidence session on 26 February 2009, The AEF would like to make the followingclarifying remarks and provide additional information:

1. In Q134, the AEF was asked by the Chair who should produce the accepted thresholds for environmentalimpacts which, if exceeded, would invalidate airspace change proposals, and how would these thresholdswould work?

In addition to the oral evidence given to the Committee, we would like to indicate that the environmentaltargets for assessing Airspace Change Proposals (ACPs) should be determined by Government. In providingits guidance to the CAA, the Government should take appropriate advice from DECC, DEFRA, theCommittee for Climate Change Committee, the Environment Agency, and have reference to other expertopinion such as the World Health Organisation. The targets should be consulted on, and originate, fromthe DfT, who would have responsibility for drawing together the most relevant evidence from the sourcesmentioned above, and from other government departments. Accountability for the delivery of these targetswould rest with the CAA. Substantive targets on environmental thresholds/limits would increasetransparency with regard to ASC procedure. For example, on local air quality- ACPs only requireinformation to be collected where there is a potential breach of legal limits on air quality that could be causedas a result of any change. This cannot be conclusively known unless some form of monitoring andassessment is undertaken as standard.

The CAA’s functions need to be clarified, with regard to their ability to examine and enforce theenvironmental aspects of ACPs, and their forthcoming environmental responsibilities as a result of thePilling review. Clarity is needed on the extent of the CAA’s environmental remit—will they be able to tacklethe consequences of intensified airspace use- for example, increased congestion, and surface access? This isimportant, as paragraph 124 of CAP 725 only currently states that ACPs may wish to make an economicappraisal of the environmental impact of a proposal- and then, only of the benefits generated. There is norequirement to make an economic appraisal of the costs of any environmental disbenefits. As it standsCAP725 cannot provide a robust or balanced assessment of the overall economic or environmental impactsof an ACP.

2. In question 165, Mr Wilshire asked about the integration of the planning process with airspace changes

The overall structure of the UK’s airspace, and the framework for how changes to this structure areimplemented, has relevance beyond the needs of aircraft operators and the passengers who use their services.Though airspace is not currently part of the town planning process, it does have implications for planningissues including:

— land use planning;

— the interactions between national and regional strategy;

— ability of regional authorities to deliver Regional Spatial Strategies (RSSs);

— on the operations of Regional Development Agencies;

— the ability of local authorities to meet national indicators on environmental performance;

— on the siting and completion of housing developments; and

— on projected population totals.

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For example, the impact of location specific changes to routes requires the collection of population data,including projected populations. The statistics for these are not always reliable, but where they can, referenceshould be made to local housing strategies, regional spatial strategies (RSSs), and the delivery plans for theaVordable housing targets which the Department for Communities and Local Government has levied onthe regions.

The inclusion of municipal buildings should be a non-voluntary requirement. The impact of changes innoise climate on hospital facilities and schools has been widely identified- therefore in order to reduce thepotential damage to service provision that may be instigated by a flight path being routed over a hospital/school etc, these should be catalogued. Local Authorities of every tier should be statutory consultees on anyACP. This should not extend to having to deliver elements of the consultation themselves, which should bethe remit of the proposer.

Local authorities currently have minimal statutory authority on aviation emissions or noise. Regulatingthese impacts is the province of the CAA. This means that the extent of community representation on thesekey issues can be limited. For example, as the 2M group pointed out, during the Heathrow inquiry, no mapsof changes to Public Safety Zones were available to the public, as flight paths for the proposed developmenthad not yet been agreed.

Expansion proposals will not be subject to full consultation whilst the public, and the local governmentoYcers who serve them, are denied detailed knowledge of these proposals. Little can be done by localcommunities can be done to reverse impacts once change is enacted. This is why the design of airspacechanges should run in parallel with any associated airport development or expansion proposal.

3. In questions 166–167, Mr Wilshire went on to critique the concept of airspace changes running in parallelto decisions on expansion, in particular those based on central government policy which were not yet planningapplications. AEF had some core evidence on this point, which we were unfortunately unable to give to timeconstraints. On the basis that central government policy will become the basis for many airport expansiondecisions under the framework proposed by the Planning Act 2008, we submit the following supplementaryevidence to the Committee.

A national Airspace master plan is essential if the Air Transport White Paper (ATWP) is to be updatedto a National Policy Statement (NPS). We understand that NATS, CAA and the DfT have already begunworking in partnership on a project to this eVect. We oVer our conditional support for the project, on thebasis of certain environmental criteria being met.

The government has consulted on a long-term airports plan. This cannot be divorced from airspace, whichin turn will impact on emerging regulation on environmental limits. It will be diYcult to assess the UK’sability to meet expansion plans without a national plan. Not only will such a plan help assess theenvironmental eYciency of the current air space structure, it will also assist in identifying whether it bestserves the economic interests of the UK.

The Air Transport White Paper (ATWP 2003, revised 2006), whilst not a planning application as such, isthe framework upon which planning decisions are likely to be based when it is converted into a NationalPolicy Statement (NPS) as part of the Planning Act 2008. It is also a statement of intent. To assurestakeholders of every stripe of its credibility and deliverability, all of its implications should be fully assessed.

Any assessment should contain comprehensive mapping of the airspace blocks and predicted traYc flowsrequired to meet the capacity increases sparked by airport expansion. As the Transport Select Committee(TSC) will have been made aware, the Civil Aviation Authority (CAA) and National Air TraYc Services(NATS) are of the view that, were all of the South East airport development plans9 to come to fruition, therewould not be suYcient airspace capacity to accommodate the scale of predicted traYc growth on the basisof current and predicted technology. (Para 28, Competition Commission’s Market Investigation of BAASubmission by the Civil Aviation Authority May 2007)

CAP 725 contains an Environmental Assessment framework, but this is not strategically aligned with theATWP. Firstly, the traYc forecasts required for Airspace Change Proposals (ACPs) are limited to five years,whereas the ATWP provides projections up to 2030. Environmental guidance for ACPs lacks clarity andrequires a more prescriptive approach, with targets and goals, set by governmental bodies and delivered bythe CAA.

It is clear that a strategic assessment of the UK’s airspace is necessary; to ensure that industrialrequirements can be met safely, without compromising the delivery of other national and regional policies.Without this, the sustainability of the ATWP cannot be properly assessed.

As the system currently stands, NATS is a service provider, tasked with meeting demand. They have dutiesto consider if various ACPs would provide an environmental improvement, but with a substantial “get outclause” indicating that air traYc management procedures or safety considerations can override thisrequirement. ACPs are frequently instigated by service users to increase capacity. NATS have no authorityto consider whether capacity increases are sustainable, especially whilst operating on a piecemeal basis. CAAand NATS are constrained in their ability to meet sustainability criteria by their duty to satisfy demandrequirements.

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Airspace is a finite resource. Safety is, by necessity, paramount. The two bodies tasked with deliveringAirspace Change have a remit to provide for growth, but, as yet, not an established environmental remit.This means environmental considerations are sidelined in favour of capacity requirements. Safety cannotbe compromised; therefore capacity/environmental conflicts should necessarily trigger further sustainabilityanalysis, at a long-term, strategic, forward looking level.

4. Q140–150 involved a discussion of noise nuisance assessment. AEF was not called to respond to thesequestions, but feels the Committee may find the additional input below useful

The AEF was represented on the Steering Group of the ANASE study. We would highlight that the peerreview critique was confined to elements of the study, and most comments related to the “stated preference”aspects which attempted to establish a monetary value. The peer review comments from the CAA andBureau Veritas did raise some concern regarding the methodology for the work assessing annoyance.Nevertheless, in publishing the report, the DfT’s Chief Economist stated “The evidence in ANASEindicates, in my view, that it is highly probable that concern (or annoyance) with a particular level of aircraftnoise is higher than found in the ANIS study in the early 1980s.This finding is in line with the emergingfindings from the European Commission’s HYENA Study”23. Aviation Minister, Jim Fitzpatrick added:“The Government accepts that noise from aircraft is a growing concern and will take into account thosepeople aVected by aircraft noise when considering the costs and benefits of future projects”24.

Given that the report found that annoyance is experienced at far lower levels than the government’scurrent threshold of 57 dBA Leq, and that annoyance is very dependent on the number of noise events, theAEF believes that it is important to (a) set lower noise thresholds as an indication of “acceptability” and(b) produce alternative metrics that show the changes in the number of noise events. The AEF is pleased tonote that the NATS consultation does provide some additional information in respect of the latter. This isvery important as no change in the area of a contour does not necessarily mean no change in the number ofevents (albeit performed by less noisy aircraft) and therefore public reaction. While the Government claims itcannot identify a point that marks the upturn in annoyance below 57 Leq, acknowledging that people aremore annoyed while continuing to rely on data from the 1980s cannot be justified. Government shouldprovide update noise thresholds as part of the revised guidance to the CAA outlined above.

The Committee may also be interested in an objective measurement for the variable impact of aircraftnoise in more tranquil areas. The Noise Gap Index comes from an Australian study, published in 2004, bythe University of New South Wales, on Aircraft Noise and Community Impacts.25 It examined whetherhealth related quality of life was worse in communities chronically exposed to aircraft noise than incommunities not exposed. The new noise index analyses aircraft noise measurements against backgroundenvironmental noise levels. It was found that communities with relatively low levels of background noisehad significantly diVerent reactions to the introduction of air craft noise than those with chronically highnoise levels.

5. General Aviation issues

The AEF was given a pre-evidence brief that General Aviation would be a line of questioning. We areaware that the time for questions was reduced as a result of a previous session over-running, so have preparedthe following to cover some of the questions the Committee may have had on this topic:

The increasing use and expansion of commercial, regulated airspace will have consequential impacts onthe general aviation community. General aviation (GA) using Class G airspace is being forced into corridorsand concentrated at lower levels. Results from the DAP Stakeholder survey 2004, on the balance of interestbetween industry stakeholders, showed that whilst Commercial aviation users gave an approval rating ofnearly 80%, only 33% of GA respondents felt DAP was Good or Excellent in balancing interests across thesectors, with 50% believing it to be Average. Airspace is not equitably shared between the sectors.

There is still a noise issue surrounding smaller airfields. Circuit training and low-flying prop planes andsmall jets all have a noise impact. Concentrating aircraft at lower levels in restricted areas will mean thatpeople living near to GA airfields will be exposed to greater noise intensity and increased incidences ofdisturbance. Where GA aircraft are routed around large tracts of regulated airspace, there is a parallelimpact on emissions and fuel usage.

There is also a potential safety issue with decreasing the volume of unregulated airspace. The CAA’sguidance on safety for unregulated airspace conflicts with some of the NATS TCNorth proposals. Theminimum recommended height to avoid bird strike (as given to GA pilots by the CAA) is 2,500ft. NATSTC North proposals included wide-bodied aircraft being given flight paths of between 2,300–3,000 foot overthe Chilterns.

23 http://www.dft.gov.uk/pgr/aviation/environmentalissues/Anase/anasechiefeconomist24 http://nds.coi.gov.uk/environment/fullDetail.asp?ReleaseID%327707&NewsAreaID%2&

NavigatedFromDepartment%False25 http://www.bbsu.unsw.edu.au/documents/AAS 2004 Conf Paper 3 formatted%5B1%5D.doc

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There are currently few established guidelines regulating flying patterns for uncontrolled airspace,although some good practice guides have recently been developed. There is little statutory enforcement.Regulatory guidelines should be published. This is of particular concern, not only to our membership, butto address the 70% of airproxes that occur in uncontrolled airspace.

March 2009

Memorandum from Stop Stansted Expansion (AIR 26)

Introduction

Stop Stansted Expansion (“SSE”) was established in 2002 in response to Department for Transport(“DfT”) proposals for major expansion of UK airport capacity, particularly in the south east. We representover 7,000 members and supporters including 140 parish and town councils, residents’ groups, national andlocal environmental groups and other organisations. We have no political aYliations.

SSE responded to the NATS’ Terminal Control North (“TCN”) Airspace Change Proposal Consultationand a copy is attached as Annex 1.

Summary of Our Evidence

— Airspace capacity is only one of the issues arising from the DfT proposals for airport expansion.

— The additional airport capacity outlined in the 2003 Air Transport White Paper (“ATWP”) is nowbased on unreliable data. This is due, inter alia, to subsequent changes in demand, oil prices,aircraft load factors and runway utilization at existing UK airports.

— The 2003 ATWP had scant regard for the need for aviation to contribute to the UK’s targets forreducing carbon emissions.

— The current approach for planning and regulating the use of UK airspace does not adequately takeaccount of the environmental harms caused by aircraft noise, emissions or visual intrusion.

— The establishment of an Airspace Master Plan would have planning benefits.

— The management of UK airspace should be more integrated with the rest of Europe including thedevelopment of UK airspace changes.

— Greater emphasis should be placed on developing new techniques and technologies, incollaboration with European air navigation service providers, to improve the capacity of UKairspace.

— There should be a smaller number of competing air navigation service providers in Europe.

— The roles of the UK interested parties in airspace design are currently unsatisfactory in thatenvironmental considerations are subordinated to commercial interests.

— Airspace implications should be considered as part of any major airport expansion proposal.

Responses to Specific Questions

1. What changes to the management of airspace could be required as a result of the additional airport capacityoutlined in the 2003 White Paper? Are the White Paper’s projections for increased passenger demand stillaccurate? Are all the measures to provide for increased passenger demand likely to be implemented?

1.1 The ATWP is a policy document whose time has passed. In 2003, the DfT was projecting an increasein UK air passenger demand from 180mppa in 2000 to about 500mppa in 2030 and, despite strenuous denialsof a “predict and provide” approach, supported airport expansion proposals to cater for 484mppa in2030.26 Seemingly, therefore, it was a policy of “predict and provide minus 3%” but it has transpired to be“predict and fully provide” because the DfT significantly underestimated the share of UK demand thatwould be handled by regional airports (and overestimated the demand upon airports serving London). TheDfT projected that regional airports would be handling 40% of UK air passengers by 2030 compared to 35%in 2000. However, regional airports achieved a 41% share in 2007,27 just four years after the ATWP waspublished and the strong regional growth trend continues.

26 Passenger Forecasts: Additional Analysis, DfT, Dec 2003, Annex B4.27 CAA airport statistics for 2000 and 2007, Table 1 in each case.

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1.2 The DfT has always viewed the rapid growth in air travel as evidence of a looming capacity problemrather than a problem of unsustainable demand growth. In addition, the DfT has never contemplated thepossibility that supply can create demand for air travel even though there is considerable evidence to supporta supply-led view of the market, particularly in the low-cost sector.28

1.3 The DfT’s projection of passenger demand of 500mppa by 2030 was based on assumptions whichwere always extremely sensitive to the economic, social and political context and the context has nowsignificantly changed. For example, the demand projection was predicated on an oil price of $25 per barreland there was scant regard in the ATWP for the need for aviation to contribute to the UK’s targets forreducing carbon emissions. With an 80% carbon reduction target by 2050 now in prospect, it is no longercredible to claim that a “predict and provide” approach to air travel can be reconciled with the Government’spolicy for tackling climate change.

1.4 There is also the question of whether there is suYcient airspace in the south east to cater for the levelof expansion envisaged by the ATWP and in this context we would draw your attention to the view expressedby the CAA and NATS in a recent submission to the Competition Commission:

“To date, all airspace change requests have been managed and implemented. However, the CAAand NATS are of the view that, were all of the SE airport development plans to come to fruition,there would not be suYcient airspace capacity to accommodate the scale of predicted traYc growthon the basis of current and predicted technology. As a consequence, airspace constraints may aVectthe future nature and degree of competition in this market.”

1.5 The DfT has also consistently underestimated the ability of UK airports to increase capacity on theexisting runway infrastructure. Progressive improvements in technology and improved operating procedureshave over the years enabled a steady increase in the number of aircraft movements that can be handled perhour and this is likely to continue to be the case.

1.6 In addition, aircraft have become larger over the years and again this trend will continue. Indeed, ashortage of runway capacity would encourage this. Tokyo International Airport (Haneda) has averagedover 200 passengers per air transport movement (“ATM”) since 2000 whereas Heathrow averages just 143passengers per ATM.29 Put another way, Haneda handles almost the same number of passengers asHeathrow but with a third fewer ATMs.30 This is largely because the two main Japanese airlines31 operateBoeing 747s with up to 563 seats on short haul routes. Such an approach obviously enables more eYcientuse of airspace.

1.7 Airspace is not the only finite resource. Britain is a small, overcrowded island and the South East isits most overcrowded part containing one third of its population in just 12% of its land area (and generating40% of UK GDP). Land use considerations therefore deserve high priority. Globally also there are finiteenvironmental limits which need to be respected and, as stated above, a “predict and provide” approachto aviation simply cannot be reconciled with the Government’s claim to leadership on the issue of tacklingclimate change.

1.8 The Government’s own advisors, the Sustainable Development Commission (“SDC”), appear tohave recognized the mismatch in aviation policy by calling for an independent commission to review theeconomic, environmental and technological evidence before any decisions on major airport expansion aretaken.32 Unsurprisingly the DfT has dismissed the SDC report, perhaps preferring not to have its evidencebase subjected to independent scrutiny.

1.9 In short, lack of airspace capacity is just one of many diYculties associated with the DfT’s proposalsfor airport expansion in the south east and in our view it would be far more fruitful to initiate a root andbranch review of the DfT’s “predict and provide” aviation policy rather than seeking to address, one by one,the many problems arising from that policy.

2. Can safety be maintained as airspace is increasingly utilized? Is there a suitable interface between militaryand civilian arrangements for air traYc control?

2.1 As indicated above, it is not necessarily the case that UK airspace should be increasingly utilized.Safety is of course of paramount importance and any intensification in the use of airspace over the southeast of England—a densely populated area and already the busiest airspace in the world—is bound to giverise to safety concerns.

2.2 SSE has no comments to make on the interface between military and civil arrangements for airtraYc control.

28 For example, oral evidence by Mr David O’Brien on behalf of Ryanair to Uttlesford District Council (“UDC”) in connectionwith BAA’s G1 planning application, UDC webcast, 4 July 2006.

29 “Transport Statistics: Great Britain, 2007”, Tables 1 and 630 Haneda handled 66.8m passengers in 2007 compared to 67.9m at Heathrow.31 JAL and ANA.32 “Breaking the Holding Pattern”, SDC, May 2008.

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3. Is the current approach to planning and regulating the use of UK airspace adequate? Would an AirspaceMaster Plan covering the period of the White Paper be beneficial? Could a piecemeal approach to individualdevelopments necessitate additional redesigns subsequently?

3.1 The current approach to planning and regulating the use of UK airspace does not adequately takeaccount of the environmental harms caused by aircraft noise and emissions or visual intrusion. It does notseek to establish a trade-oV between benefits to the user (ie the airlines) and environmental harms to thecommunity and certainly does not provide environmental benefits to the community. This issue is furtherdescribed in our attached letter to the CAA (Annex 2).

3.2 It is considered that an Airspace Master Plan covering the period of the ATWP would be beneficial.It is untenable that the 2003 ATWP extends to 2030 and yet the 2008 major TCN Airspace Change Proposalonly has a horizon of 2014. This means that the full implications of airport expansion proposals cannot beunderstood by local communities and others. The information is simply not available at the planning inquirystage. It is also desirable to maintain stability of air routes over as long a period as possible in order to bringgreater certainty to land-use planning, the housing market and noise-sensitive development in general.

3.3 It would be more eVective if individual airspace developments were reviewed against the backclothof an Airspace Master Plan. There should be a computer model of the whole of UK airspace such that likelyfuture scenarios can be tested and redesigns validated within the whole system.

4. How are the eVects of aircraft noise and emissions taken into account when changes are made to the use ofairspace? Who should be consulted about such changes? How should the balance between conflicting interestsbe struck?

4.1 The eVects of aircraft noise and emissions are not adequately taken into account when changes aremade to airspace. A current example of this inadequacy is the NATS’ TCN Airspace Change Proposal. Themethodology used by NATS to calculate the population aVected by noise is flawed and underestimates theadverse impact. Its methodology for estimating the fuel burn/emissions per flight shows a neutral result intotal across a region of over 12 million people. That means there will be no overall environmental benefitfor these changes throughout the whole system. The proposed new routes for aircraft using Stansted Airport,for example, would increase the total track mileage in this region by an average of 2,500 per day. This clearlyhas environmental disadvantages both to local communities and the world at large. Further informationconcerning this issue is given in our attached letters to NATS and the CAA.

4.2 In the case of the TCN Consultation, the NATS’ Initial Feedback Report dated July 2008 showed thatover 15,000 responses were received and that 86% of the members of the public and 77% of the representativegroups were opposed to the changes. NATS identified 27 key themes in the responses. For the representativegroups, the three main themes for objection were tranquillity, aircraft noise in general and noise over ruralareas. The fourth main theme was climate change and CO2 emissions and significantly the fifth main themewas the development/consultation process itself. The public’s main themes for objection followed a similarpattern with tranquillity and noise over rural areas ranking significantly above the other issues.

4.3 If a conflict is found to exist between user eYciency gains and environmental gains, priority shouldbe given to delivering environmental gains.

4.4 In SSE’s opinion the NATS’ TCN Airspace Change Proposal Consultation was flawed. One of thedeficiencies was the inadequate involvement of the public and their elected representative bodies. This isfurther discussed in our attached letter to the CAA (Annex 2). There needs to be a fundamental improvementin this process which should also be carried out against the backcloth of an Airspace Master Plan.

5. How does the management of airspace in the rest of Europe aVect flights into the UK? Is there an opportunityto integrate our plans for changes to airspace management more eVectively with those of other Europeancountries?

5.1 The management of airspace in the rest of Europe aVects flights into the UK and ideally this totalcontinuum of airspace should be seamless. Upper airspace can be managed in what are termed largefunctional blocks and this principle should be extended as widely as possible. It is operationally andtechnically possible to safely and eYciently control air traYc throughout Europe both for en-route traYcand traYc in the terminal marshalling area without the current plethora of Air TraYc Control Centres inevery country. A smaller number of pan-European centres should undertake the task and this would alsobring cost savings such that airlines would pay lower user charges.

5.2 An example of good European integration is the Eurocontrol Central Flow Management Unit inBrussels which, through co-ordinated management of the air traYc throughout Europe, seeks to minimisecongestion in the air and make the most eYcient and eVective use of available capacity.

5.3 A smaller number of centres each having control over a larger volume of airspace throughout Europewould necessitate an integrated approach to air traYc management, including the development of UK plansfor airspace changes.

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6. What opportunities are there to apply new techniques and technologies to reduce wasteful flying on indirectroutes and excessive “stacking” while planes wait to land? How can the potential of any such opportunities bestbe realized? Could environmental benefits be gained as a result of such improvements?

6.1 A considerable amount of research and development eVort is currently underway in Europe on newtechniques and technologies to improve the eYciency of air traYc management through improved controllertools, for example, reduced separation minima, flight trajectory prediction, tailored arrival procedures andair traYc flow and capacity management (optimizing network capacity through collaborative decisionmaking processes). In addition there have been considerable advances in aircraft flight deck avionics usingsatellite technology for improved communication, navigation and surveillance.

6.2 Better dynamic flight planning is the key to avoiding wasteful flying on indirect routes and excessivestacking. This requires the early introduction of improved controller tools and an integrated “end-system”approach between the ground and airborne systems. Such tools would provide a much more eVective “gateto gate” operation and reduce wasteful flying.

6.3 When considering the stacking problem, it is often asked why aircraft are allowed to leave thedeparture airport only to be subsequently stacked whilst waiting to land at the arrival airport. The aircraftshould not have been allowed to depart in the first place. The introduction of new controller tools wouldenable the flow and capacity of the total system to be more eVectively managed.

6.4 The realization of these potential improvements will require a more collaborative approachthroughout Europe and a greater willingness to standardize on system architecture and solutions.Additionally the timescales from initial design to introduction into service of ground based ATM equipmentare too long and need to be speeded up.

6.5 Reduced stacking would clearly bring environmental benefits and provide an opportunity to deliverenvironmental benefits through more sensitive routing and sequencing.

7. In relation to the redesign of UK airspace, is the allocation of the roles and responsibilities of each of theinterested parties—Department for Transport, the CAA, airport operators, NATS, etc—appropriate andclearly understood? Are the structures of the parties appropriate for undertaking the roles that they should play?

7.1 The change process for the redesign of airspace is set out in CAP 72533 and NATS is the sponsor forthe current TCN Airspace Change Proposal. In our letter to the CAA (Annex 2), we draw attention to anapparent conflict of interest whereby NATS is a limited company controlled by BAA and seven major UKairlines. Furthermore, the shareholder objectives focus on eYciency considerations and do not include anyenvironmental objectives. We regard this as an unsatisfactory state of aVairs whereby environmentalconsiderations are subordinate to the commercial interests of the aviation industry shareholders. Thissubordination is manifest in the TCN proposals where there are clearly potential cost savings for airlinesbut significant adverse environmental consequences for the community in terms of aircraft noise, emissionsand visual intrusion, aVecting over 12 million people.

7.2 The change process has to undergo regulatory assessment by the CAA before any approval can begiven and the changes then require to be approved by DfT. However, the CAA has no environmental remitand we have little confidence in the DfT to act as a guardian of environmental interests when its main focusis upon promoting the interests of the UK aviation industry. Consideration should be given to involvingDEFRA, DCLG or the new department for Energy and Climate Change in the process.

8. Do airspace management considerations delay the planning processes in relation to airport developmentproposals? How will airspace management considerations be taken into account by the proposed newInfrastructure Planning Commission and the relevant National Policy Statements on airport planning?

8.1 Airspace management considerations are currently outside the scope of the planning process and soshould not give rise to any delays in the planning process, except insofar as their exclusion gives rise tomisunderstandings and arguments. As we have argued above, we believe it is quite wrong that airspaceimplications cannot be considered as part of any proposed major airport expansion project. An AirspaceMaster Plan would be a useful tool in informing planning decisions—whether dealt with by the presentplanning system or by the proposed new Infrastructure Planning Commission.

9. What could be the implications for smaller airfields, recreational flying and helicopters if changes to airspacemanagement to enable safe and eYcient increases in capacity at the UK’s major airports? How should anappropriate balance between conflicting priorities be determined?

9.1 No comment.

33 CAA Guidance on the Application of the Airspace Change Process, 30 March 2007.

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10. Will it be possible to recruit and train staV in order that airspace changes can be implemented in parallelwith additional airport capacity?

10.1 No comment.

11. Who should fund airspace changes? Is there likely to be enough funding to undertake the redesign requiredto bring about the necessary additional airspace capacity?

11.1 The air navigation service provider should fund airspace changes and recover the costs throughuser charges.

11.2 A smaller number of European air navigation service providers competing for fixed term contractsfor the provision of air traYc control over larger blocks of airspace would be a more cost eVective way ofoperating European airspace.

October 2008

Memorandum from the Strategic Aviation Special Interest Group (AIR 27)

Introduction

SASIG is the Strategic Aviation Special Interest Group of the Local Government Association (LGA) witha membership of 54 Local Authorities representing 14 million people, or approximately a quarter of the UKpopulation.SASIG seeks to ensure that any national aviation strategy for the UK is implemented through regionalplanning guidance and other planning processes so as to reconcile economic, social and environmental issuesin a sustainable way.

SASIG’s Key Recommendations

— Early assessment of airspace requirements

Aviation proposals resulting in increased capacity must be supported by assessment of the airspacerequirements.

— Production of an Airspace Master Plan for the UK

An Airspace Master Plan for the UK should be drawn up using robust, independent evidence, andintegrated fully into a review of the 2003 Aviation White Paper. This Airspace Master Plan shouldalso inform the production of a National Policy Statement for aviation.

— Greater understanding and consideration of community impacts of aviation

Increasingly congested airspace should, where necessary, lead to capacity constraints for reasonsof safety and environmental protection.

Responses

1. The additional airport capacity outlined in the 2003 Air Transport White Paper (ATWP) necessitatesconsideration of airspace for the associated increase in air transport movements. These considerations werenot made in preparation for the White Paper, and to date the airspace requirements for the ATWP proposalshave still not been assessed.

Earlier this year, NATS consulted on proposals for airspace changes associated with Stansted, Luton andLondon City airports—the Terminal Control North (TCN) airspace block. Despite this being one of thelargest airspace change proposals undertaken for the UK, it did not address the ATWP proposals for theairports within TCN.

The shortcomings of the TCN airspace change proposal, in terms of longevity, consideration of futuredevelopment on the ground, consultation support and public engagement, and overall environmental gains,must be addressed in subsequent airspace consultations.

Further research and consideration of the viability and impacts of rural routing being used in preferenceto flying over urban areas is required. This may require revisions to current strategic guidance.

The growth projections outlined in the 2003 ATWP may or may not be met. Revised forecasts are requiredto future-proof the ATWP proposals—a Progress Report is not suYcient; a full review of the proposals isrequired to provide for long-term, robust, strategic planning, in place of the piecemeal, incrementalproposals in the ATWP. Reassessment of oil prices and the increasingly unpredictable marketplace arerequired to ensure that the capacity that is provided is actually used. This would reduce pressure on airspaceoperators to provide capacity beyond safe and environmentally sustainable levels.

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EU-wide airspace blocks could provide for an increase in capacity, as could estuary airport solutions, andover-seas stacking. These elements should all be assessed in terms of airspace management considerations.

2. Safe operations must be maintained at all times. As routes become increasingly congested, safetyrequirements must not be compromised and penalties for level-busts must be severe. This should be takeninto consideration when deciding on the location of new capacity. Amongst other issues, capacity increasesmay aVect the size and location of local Public Safety Zones, and thus land-use planning decisions.

The operational interface between military and civilian arrangements for air traYc control must providefor the most eYcient use of airspace, taking account of safety, environmental, social and economicconsiderations.

3. The planning and regulation of UK airspace requires long-term strategic support. This means that anAirspace Master Plan, based on comprehensive and independent evidence, covering at least the period of theAviation White Paper but ideally to 2050 and possibly beyond, is needed. Without this, it remains diYcult todetermine whether or not the White Paper projections can be safely met. The Airspace Master Plan shouldbe used to inform the production of a National Policy Statement for aviation, and should address, forinstance, the following elements: maps of airspace blocks across the UK in association with airfields; thecurrent air quality and noise emission conditions in each block; the relevant limits to not be breached forair quality and noise conditions in each block; the measures needing to be implemented to manage andreduce noise and air quality in each block; and following consideration of the aforementioned prerequisiteelements, the current and potential capacity per block in terms of air transport movements by type.

To date, airspace has been considered on a piecemeal, incremental basis, and a national overview is veryoverdue. A UK Airspace Master Plan should be used to inform the airspace considerations that should beprovided in support of development proposals.

4. The eVects of aircraft noise and emissions on local populations are not given equal footing withcapacity considerations. There should be accepted thresholds for environmental impacts which, if exceeded,would invalidate Airspace Change Proposals. More hard evidence should be gathered to ensure thatenvironmental impacts are considered on a par with economic and safety statistics. Local Authorities shouldprovide input to the collection of that evidence, and be key consultees for Airspace Change Proposals.

5. Better integration with EU airspace is necessary if coastal stacking is to be an option. A singleintegrated EU airspace block would increase eYciency by allowing controllers to better regulate the speedof traYc arriving in UK airspace.

6. The environmental gains to be achieved from the Terminal Control North airspace change areminimal, and in contrast to the environmental impacts of the growth envisaged, particularly in alreadycongested airspace. Greater emphasis should be placed on maintaining environmental standards, whichshould not be considered as subsidiary to capacity constraint considerations. It is disappointing that theincreasing use of Controlled Descent Approaches (CDA), Precision Area Navigation systems (PR-Nav),and other technological advances, have not led to more significant environmental gains. Further assessmentof these technologies is required to fully understand the extent and impacts of their use, particularly in termsof the community impact of aircraft noise.

7. Provision of expert advice and data needs to be made earlier in the consideration of developmentproposals. Currently, NATS is the main airspace control provider, and as such should be required to providedata to inform airspace considerations in relation to development proposals. NATS’ advice regardingcapacity limitation should take precedence over externally set growth targets.

In order for the CAA to strengthen its reviewing process of actual operations, it must be appropriatelyresourced, to enforce adherence to their CAP 725 Airspace Change Process Guidance.

8. Under current arrangements, airspace management is given no consideration in airport developmentproposals. In order to make informed, robust decisions on such proposals, it is necessary for airspacemanagement considerations to be provided prior to decisions regarding consent or refusal being made. Theissue is not one of delay, more a matter of having the necessary information available at the correct pointin the process.

The Aviation National Policy Statement should contain a fully comprehensive UK Airspace Master Plan.

The proposed new Infrastructure Planning Commission (IPC) is intended to consider only those projectsdefined as Nationally Significant Infrastructure Projects (NSIPs). There will be a need for coordinationbetween the IPC, airspace control provider(s), the CAA, Local Authorities, the Department forEnvironment, Food and Rural AVairs (Defra), the Department for Communities and Local Government(DCLG), and the Department for Transport (DfT).

9. Allocation of a greater proportion of airspace to commercial operations will reduce to some extent theairspace available for smaller airfields, recreational flying and helicopters. This could in turn lead to a lackof training opportunities and a subsequent skills and employment shortfall. It is essential that publicconsultation adequately captures the community impact of overflying—area that still requires furtherresearch and consideration. Assessment and monitoring of the impact of new routes and altitudes is essentialin order to inform an appropriate balance between such conflicting priorities.

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10. It should be possible to resolve personnel issues such that airspace changes can be implemented inparallel with additional airport capacity.

11. Those who benefit from additional airspace capacity should fund changes. If carriers want greatercapacity, they should invest in safe routes—the same applies to airports looking to attract more carriers.Central Government backing should be made available to ensure safety standards are maintained.

October 2008

Memorandum from The Boeing Company (AIR 28)

Boeing is pleased to submit evidence to The House of Commons Transport Committee’s inquiry into theuse of airspace. This response includes a discussion of airspace utilization issues and is based upon existingfeatures on current Boeing and other commercial aircraft as well as extensive research and technologyprogrammes.

General Information

1. Boeing is the world’s leading aerospace company and the largest manufacturer of commercial jetlinersand military aircraft, with capabilities in rotorcraft, electronic and defence systems, missiles, satellites,launch vehicles and advanced information and communication systems. Our reach extends to customers in145 countries around the world, and we are the number one US exporter in terms of sales. Headquarteredin Chicago, Illinois, USA, Boeing employs more than 160,000 people in more than 70 countries.

2. Boeing has a long standing relationship with the UK dating back over 70 years and today the UKremains a critically important market for the company, as a supplier base and a source for technologypartners. Boeing’s annual spend in the aerospace industry supports thousands of jobs around the UK, inthe process generating intellectual property and facilitating exports.

3. Boeing sources more from the UK than from any other country in the world, except the USA. Typicallyin the UK, the company sources up to $3 billion of services and materials from around 300 UK suppliers.There are currently more than 650 Boeing UK employees, in locations from Almondbank to Gosport.

Boeing Commercial Airplanes

4. Boeing Commercial Airplanes (BCA) is the world leader in commercial aviation because of itscomplete focus on airplane operators and the passengers they serve. Boeing products and services deliversuperior design, eYciency and support to airline customers and allow passengers to fly where they want togo, when they want to go. By working together with supplier partners from around the world, Boeing hasdelivered more than 15,000 airplanes to customers worldwide including airlines, leasing companies,governments and private firms.

5. Boeing Commercial Airplanes is headquartered in Renton, Washington, under the leadership ofPresident and Chief Executive OYcer, Scott Carson. It is organized into three primary business units—787Program, Airplane Programs and Commercial Aviation Services—as well as providing Airplane Tradingservices.

Airspace Optimization

1. Air safety can and must be maintained as airspace is increasingly utilized. This is the aviation industryrecord and Boeing expects this emphasis to continue. There are new ATM technologies that will not onlysupport increased utilization but will yield new opportunities for environmental improvements bypromoting the most eYcient possible use of the airspace system in terms of fuel savings and noise reduction.

2. The eVects of aircraft noise and emissions are taken into account when changes are made to the use ofairspace. These changes are generally preceded by consultations with aviation stakeholders. This processresults in the presentation of relevant facts, data, and opinions which the UK government takes into accountbefore choosing a course of action. This UK process has the additional advantage that it helps ensureadherence to the ICAO Balanced Approach, which requires airports and governments to consideralternatives before imposing operational restrictions and/or noise and emissions reductions at the source.

3. When changes to airspace are proposed, interested aviation stakeholders should be consulted for facts,data, and opinions. It is especially important to consider, in some detail, the impact of airspace changes tonoise and emissions and the resulting eVect on residents and national environmental goals or targets.

4. Boeing recommends that a balance of conflicting interests can be struck by the Government on airspaceutilization issues, however it must promote the most eYcient transfer of goods and services possible withinthe global air transport system without compromising safety.

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Ev 176 Transport Committee: Evidence

5. There are opportunities to apply new techniques and technologies to reduce wasteful flying on indirectroutes and excessive holding. There is significant opportunity to integrate new ATM capabilities into anoperational model for London TMA. These capabilities, such as RNP and RNAV, coupled with ATM re-design will support the reduction of delay (holding stacks), improve environmental performance (CDA’s andTailored Arrivals), and allow more direct flight routing.

6. These opportunities will best be realized through the integration of airspace design and airplanecapability. These actions in conjunction with regulation harmonization will allow timely implementation ofthese capabilities.

7. Boeing believes that there are airspace operational and environmental benefits to be gained as a resultof such improvements. The evidence is clear that any reduction in indirect routes or excessive delay willprovide environmental benefits. Continuing the status quo will result in greater fuel burn than theoreticallynecessary, with a direct increase in emissions. What may be less apparent is that reducing indirect routes willtend to result in less fuel capacity needed at takeoV, reducing takeoV weight and departure noise exposure.Reducing excessive holding, particularly if combined with Continuous Descent Approach starting from topof descent, coupled with other airspace optimization will tend to result in less noise exposure under the flightpath on approach.

Conclusion

8. Overall Boeing believes that there is scope for improving the operational performance of Britain’sairspace, as there is for many countries around the world. Much of the technology that can deliverimprovements is in existence today and Boeing is actively working with air traYc service and airline partnersin particular. Further information is available from Boeings’ corporate oYce at 16 St James’s Street,London, SW1A 1ER.

October 2008

Memorandum from the National Air TraYc Service (NATS) (AIR 29)

1. Introduction

1.1 NATS is the UK’s leading provider of air traYc management services. We are regarded as a worldleader in our industry, voted in 2007 the best Air Navigation Services Provider (ANSP) in the world in anindependent survey of the industry including other ANSPs, systems manufacturers and airlines.

1.2 NATS was established as a PPP in 2001 and is now owned 49% by the UK Government, which alsomaintains a Special Share; 42% by The Airline Group, a consortium of UK airlines; 5% by its employees,and 4% by BAA.

1.3 NATS comprises two businesses. NATS En Route plc (NERL) is the monopoly provider of en-routeair traYc services in the UK and the north east quadrant of the North Atlantic, provided under licence from,and regulated by, the Civil Aviation Authority (CAA); NATS Services Ltd (NSL) is NATS’ non-regulatedbusiness providing air traYc services at many UK airports and is NATS’ interface with the wider UK andglobal ATM markets.

1.4 The terms of NERL’s licence from the CAA require the company to be capable of meeting on acontinuous basis any reasonable level of overall demand. NERL is charged under its licence with permittingaccess to airspace on the part of all users whilst making the most eYcient overall use of airspace.

1.5 In other words, NATS’ job is to meet the air traYc service requirements of airlines and others usingUK airspace, including the Military, and to control traYc safely and eYciently. NATS does not establishairspace policy, which is the responsibility of the Directorate of Airspace Policy (DAP) at the CAA.

1.6 NATS welcomes the Committee’s interest in the use of airspace, and this opportunity to contributeanswers to your questions as part of your inquiry. We would also like to renew our invitation to theCommittee to visit the Swanwick Centre to help inform your debates.

2. Summary

2.1 NATS’ submission to the Committee responds to the questions posed and we would be happy toprovide further explanation should the Committee find that helpful. In summary, our responses make thefollowing points:

— Airspace design is complex and must accommodate many interactions; it requires significantplanning.

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— Airspace in south-east England, in particular, is the most complex in the world and if all the airportmaster plans accounted for in the White Paper come to fruition at the maximum capacity, therewill not be suYcient airspace capacity to accommodate the scale of forecast traYc growth on thebasis of current and predicted technology, without the imposition of delays and a reduction inoverall eYciency.

— Airspace requirements—and constraints—must be recognised in the earliest stage of aviationpolicy making.

— Airspace is as important a part of the airport infrastructure as runways and ground access andmust be factored in to consideration of airport expansion.

— Detailed airspace design requires specialist expertise; this is a costly resource which must be usedeVectively and is only applied once policy has been clarified.

— Greater clarity is required in some areas of Government policy, notably environmental policy onmatters such as concentration/dispersal of noise and relative importance of noise/emissions; thisin turn will enable clearer guidelines provided by the CAA for airspace design and future airspacerule-making.

— Priority should be given to maximizing the capacity of existing infrastructure, rather than buildingnew infrastructure; new capacity provided through new runways can be used to build resilienceinto airport operations, particularly at busy airports such as Heathrow.

3. Responses to the Committee’s Questions

3.1 What changes to the management of airspace could be required as a result of the additional airport capacityoutlined in the 2003 White Paper?

3.1.1 Any changes to airspace would be dependent on the nature and extent of any specific plannedairport expansion. A sizeable expansion may well require new procedures which would trigger an AirspaceChange Proposal, the formal process under CAA guidelines which airspace change sponsors, such as NATS,follow for all airspace development.

3.1.2 A major limiting factor to increasing airspace capacity in the South East is the complex interactionsbetween routes serving a large number of airports within a relatively small geographical area. To date, allairspace change requests have been managed and implemented, but ultimately NATS agrees with the CAAthat if additional runways are built at Heathrow and Stansted, and if, in the unlikely event, all of the otherSE airport master plans accounted for in the White Paper come to fruition at the maximum capacity, therewill not be suYcient airspace capacity to accommodate the scale of forecast traYc growth on the basis ofcurrent and predicted technology, without the imposition of delays and a reduction in overall eYciency.

3.1.3 NATS has not carried out detailed work to assess individually the airspace implications of any ofthe airport expansion proposals currently being considered (eg a third runway at Heathrow or a secondrunway at Stansted). Until a decision is made on these significant developments, there is no basis for carryingout this extremely labour-intensive and costly work.

3.1.4 Airspace changes are undertaken only when necessary and take account of traYc growth since theprevious change, as well as acknowledging the general forecast increase in traYc volumes. For instance, therecent proposals for the Terminal Control North area (the most complex area of airspace in the world) werenot designed to support runway expansion at any individual airport, but to reflect the growth in air servicesover the past 15 years, as well as accommodating the forecast air traYc arising from general airport growthunder the provisions of the White Paper.

3.1.5 Changes that may be required could include revised route structures, airborne holds (or stacks) andflight paths to give greater consistency of aircraft tracks, to segregate and separate flight paths, improveoperational eYciency, increase capacity/reduce pre-departure delay, enhance safety and reduceenvironmental impact.

3.1.6 In terms of airspace management, NATS would apply new techniques and tools to support the mosteYcient use of any new routes and airspace. This includes:

— Greater use of support tools to accurately manage the integration of arrival and departure flows.

— Greater co-operation and data sharing between all elements of the network (ATC, airportoperations and aircraft operators—otherwise known as Collaborative Decision Making (CDM).

— Greater data sharing, interoperability and co-operation between adjacent ANSPs for betterdelivery of aircraft into the south-east.

— Better integration of aircraft from smaller airports into the network to reduce the impact of aircraftusing busy airports.

— Application of performance based navigation requirements on aircraft to reduce distances betweenflights and improve the accuracy of the tracks flown.

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3.2 Are the White Paper’s projections for increased passenger demand still accurate?

3.2.1 This is not a matter for NATS.

3.3 Are all the measures to provide for increased passenger demand likely to be implemented?

3.3.1 This is not a matter for NATS. However, it is important that NATS makes it clear to policy makersthat the projections and aspirations of airport operators will ultimately aVect strategy and airspace designrequirements and capabilities, and that therefore policy decisions must reflect clear priorities.

3.4 Can safety be maintained as airspace is increasingly utilised?

3.4.1 NATS’ first priority is safety and this will not be compromised; as airspace becomes increasinglyconstrained, so safety is assured by reducing the number of aircraft in the system, which leads to theintroduction of flight delays. However, whilst airspace capacity is a finite resource, it will increase safely overthe next 30 years or so through improved procedures and new technology and ATC tools.

3.5 Is there a suitable interface between military and civilian arrangements for air traYc control?

3.5.1 The civil/military interface in the UK is extremely good, and significantly better than anywhere elsein Europe. Military controllers share NATS’ centres and the level of interaction is high with the introductionof initiatives such as flexible use airspace. However, it is certainly true that the level of demand outlined inthe White Paper will require even greater flexibility to accommodate civil flights during peak periods. NATS’ability to feed traYc into Europe can be inhibited by other countries’ military activities, so better co-operation between adjacent States would be helpful. Whilst the ATC arrangements are eVective,Government must recognise that policy on military matters, eg the location of bases, may also aVect airspaceeYciency.

3.6 Is the current approach to planning and regulating the use of UK airspace adequate?

3.6.1 There is a need for a review of regulatory process with a fast track process for changes that supportnational transport policy statements. NATS accepts the importance of public scrutiny of proposals that canaVect flight paths over communities; however the current system is very susceptible to repeated and extendedchallenge which can seriously compromise the need for change within reasonable time limits and severelyconstrain the development of airspace in support of wider policy objectives.

3.7 Would an Airspace Master Plan covering the period of the White Paper be beneficial?

3.7.1 It is essential to have an Airspace Strategy, or master plan, owned by the CAA and which describeshow it will address the objectives of the White Paper, albeit that the White Paper is aspirational. In orderfor such a strategy to form an eVective basis for planning assumptions, it needs clear policy direction onpriorities between operations at diVerent airports. NATS’ airspace development programme should deliverthis airspace strategy.

3.8 Could a piecemeal approach to individual developments necessitate additional redesigns subsequently?

3.8.1 This would be a risk to longterm stability in airspace development, particularly in airspace ascomplex as in southeast England where there are many inter-leaving routes and competing airports. Thismakes it diYcult to provide a complete picture of change and to plan eVectively.

3.9 How are the eVects of aircraft noise and emissions taken into account when changes are made to the useof airspace?

3.9.1 NATS is establishing a set of environmental best practices for airspace design. Whilst we have in-house expertise we also sub-contract external agencies to ensure we fully meet CAP 725 requirements interms of noise, emissions and Local Air Quality assessments.

3.10 Who should be consulted about such changes?

3.10.1 The current regulatory process requires change sponsors to liaise with CAA DAP on consultationrequirements which may vary depending upon the scale of the proposed change. NATS believes that airspacechange in support of nationally agreed transport policy decisions should be conducted with appropriaterepresentative bodies, local authorities and aviation stakeholders. Feedback from the recent TCNconsultation shows that representative local authority bodies whom NATS consulted are representing theviews of their electorate and raised the same issues as members of the general public. This does not restrictthe right of individual members of the public to make their own representations on information provided.

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3.11 How should the balance between conflicting interests be struck?

3.11.1 The White Paper represents the best opportunity to date to ensure that new airport capacity canbe used to build resilience into the system and to reduce the amount of airborne holding. NATS as airspacedesign experts believes it is ideally placed to ensure safety, and strike the right balance between providingcapacity and minimising environmental impact. More rigorous environmental guidance, particularly on thebalance between emissions and noise, will support this approach, whilst air transport policy should stateclear priorities.

3.12 How does the management of airspace in the rest of Europe aVect flights into the UK?

3.12.1 The UK contributes a significant percentage of aircraft into the core of Europe, not only throughlocal European traYc, but also because of its unique position as Europe’s primary North Atlantic gateway.The eYcient transfer of aircraft from one ANSP to another can fundamentally aVect the capacity of theATM system. Single European Sky developments will further reinforce close working together by adjacentstates to develop the most eYcient procedures to ensure seamless transfer of aircraft across boundaries.

3.13 Is there an opportunity to integrate our plans for changes to airspace management more eVectively withthose of other European countries?

3.13.1 NATS is fully committed to working with European partners to enhance the ATM system and isa leading participant in SESAR and FAB development. The proposed network management role in the newSingle European Sky proposals will help embed best practice.

3.14 What opportunities are there to apply new techniques and technologies to reduce wasteful flying onindirect routes and excessive “stacking” while planes wait to land?

3.14.1 Stacking is caused by more traYc arriving at an airport than the runway(s) can support; it enablescontrollers to ensure there is a pool of aircraft available to maintain the optimum use of runway space atbusy airports. For instance at Heathrow, the runway is scheduled at a rate of 99% of available capacity basedupon an average holding period of 10 minutes.

3.14.2 NATS is developing new tools and working with other ANSPs and airlines to enhance arrivalmanagement to reduce the need for airborne holding, as well as mitigations to reduce the impact of holdingsuch as Required Navigation Performance (RNP) procedures to minimise environmental impact of noise,Continuous Descent Approaches (CDA), new tools to meter and manage departures to reduce groundholding and provide eYcient flows through points to provide better climb and descent profiles and improvecapacity, and new closely spaced routes to manage flows.

3.15 How can the potential of any such opportunities best be realised?

3.15.1 Building resilience into airport operations is vital—ie not scheduling to maximum capacity; or byincreasing capacity. New arrival and departure procedures using new technology which is underdevelopment will also contribute, as will greater collaboration between ANSPs to develop systems andprovide economies of scale in development and deployment (such as through SESAR in pursuit of the singleEuropean sky).

3.15.2 It is also vital to work with the Regulator to be proactive in developing and approving suchprocedures well ahead of actually needing them and, where necessary, mandating equipment to ensureconsistency of application.

3.16 Could environmental benefits be gained as a result of such improvements?

3.16.1 Yes, however we need to be clear about the nature of any benefits notably the diVerent focus onnoise, fuel burn, air quality that is achieved in certain phases of flight (to assist understanding of the design)as not all can be achieved in busy and complex airspace. A clear policy direction from Government is alsoessential to set environmental priorities as a framework.

3.16.2 NATS is the first air navigation services provider in the world to set an environmental target, toreduce ATM CO2 for aircraft under our control by 10% by 2020 against a 2006 benchmark. Benchmarkingwork will be complete by the end of this year.

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3.17 In relation to the redesign of UK airspace, is the allocation of the roles and responsibilities of each of theinterested parties—Department for Transport, the CAA, airport operators, NATS, etc—appropriate andclearly understood?

3.17.1 It takes significant time and resource to develop and implement airspace change (following theairspace change process guidelines contained in CAP725) in order to support any national policy decisionson airport growth. NATS believes these considerations can be underestimated by the Department forTransport and by the DAP.

3.17.2 The DAP’s consultation guideline document, CAP725, is intended to be a living document to beupdated in the light of experience. In NATS’ view these guidelines should now be reviewed, particularly inlight of the recent consultation on proposed changes to airspace in the Terminal Control North region ofsouth-east England where environmental direction and guidance, in particular, was unclear.

3.17.3 A more pro-active approach to translating Government policy into practical guidance will helpensure that potential future airspace requirements to accommodate growth are known and acted upon in atimely manner.

3.18 Are the structures of the parties appropriate for undertaking the roles that they should play?

3.18.1 DiYcult decisions lie ahead and NATS requires ongoing reassurance that the DfT and DAP aresuYciently organised and resourced to provide the necessary guidance and policy direction, and properlyequipped to make the necessary decisions within realistic timescales.

3.19 Do airspace management considerations delay the planning processes in relation to airport developmentproposals?

3.19.1 The current process builds in the potential for three separate sets of consultation on the same policydecision—first the Government policy decision itself, second the airport operator’s planning application(with possibly a public inquiry) and third, following approval, the airspace implications of the development.

3.19.2 NATS will provide feasibility studies to help policy and planning decisions; for instance NATSprovided the DFT with feasibility studies for its consultation in autumn 2007 on the future of Heathrow.However, airspace design is extremely costly and NATS cannot undertake detailed work until after a policydecision is made on the development itself; whilst this does not delay the planning process, it must befactored into the timescale for any development proposal.

3.19.3 It is important that decisions on airport development are taken with the understanding of potentialairspace development timescales, ie design development, consultation requirements, possibility of JudicialReview.

3.20 How will airspace management considerations be taken into account by the proposed new InfrastructurePlanning Commission and the relevant National Policy Statements on airport planning?

3.20.1 So far as NATS is aware, it has been decided not to bring airspace management within the remitof the Commission. However, NATS will play a full role in ensuring that the Commission is fully informedon the airspace implications of any development provided we know well in advance of any decision and thatwe are an integral consideration in the decision making process.

3.21 What could be the implications for smaller airfields, recreational flying and helicopters of changes toairspace management to enable safe and eYcient increases in capacity at the UK’s major airports?

3.21.1 Any increase in capacity by commercial airports puts additional pressure on airspace and can leadto a requirement to establish additional Controlled Airspace (CAS). This inevitably aVects militaryoperations, smaller airfields and recreational flying and so any decision on airport expansion must be takenwith a full understanding of national transport policy/ priority and the airspace implications assessed byNATS.

3.21.2 Whilst NATS is responsible for traYc operating in CAS, our operating licence requires us toprovide access to airspace for all users. Our airspace design proposals aim to make minimum demand foradditional CAS.

3.22 How should an appropriate balance between conflicting priorities be determined?

3.22.1 NATS is responsible for the safe and eYcient management of controlled airspace, not for policy.In developing airspace, we ensure safety, and apply a balance between delay/capacity and the environmentwhilst ensuring the key objectives for the design are met. That balance will need to be assessed by the DAPwhen an ACP is delivered (assuming current process is followed), satisfying its statutory obligations.However, clearer guidance to support the national policy decision will assist this balance to be struck.

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3.23 Will it be possible to recruit and train staV in order that airspace changes can be implemented in parallelwith additional airport capacity?

3.23.1 Airspace design expertise is in very short supply to deliver significant change, especially given thenew ATM techniques being developed which will deliver more technical rather than procedural solutions toproviding capacity. Creating that expertise is costly and it is a delicate balance to ensure that suYcientdesigners are available to meet expected demand; advance planning and a sensible sequential approach toairport development are therefore essential.

3.23.2 In terms of controller availability, NATS’ standard processes ensure that suYcient controllers areappropriately trained for delivery to the operation in a timely manner.

3.24 Who should fund airspace changes?

3.24.1 Airspace change is generally required because of expansion by airports or airlines. Airport ownersgenerally fund changes required by their expansion, within their own control zone; funding for en-routechanges required to accommodate that expansion and to increase eYciency in the face of growing volumes,required under NATS’ licence, is recoverable through route charges to airlines, which are set for five-yearperiods through NATS’ regulatory review by the CAA. This seems to be an equitable way of fundingrequired change; it also ensures that only necessary change is undertaken.

3.25 Is there likely to be enough funding to undertake the redesign required to bring about the necessaryadditional airspace capacity?

3.25.1 This depends on the scale and timescale of redesign required and whether the process can beaccommodated through the five-year funding mechanism in NATS’ licence. The scarcity of skilled airspacedesigners means that in the unlikely event of all airports wishing concurrently to expand in line with theirmasterplans, this will place pressure on NATS’ resources, and therefore on funding.

4. Additional Information: New Airport in the Thames Estuary

4.1 NATS also anticipates that the Committee may wish to explore the Mayor of London’s proposal tobuild a Thames estuary airport and to close Heathrow.

4.2 NATS has always been clear that we believe the UK should maximise its existing airportinfrastructure rather than building new airports. Airspace is too often the forgotten factor in considerationof aviation expansion, particularly airport development. Airspace is often as constrained as groundinfrastructure, particularly in the congested airspace of south-east England, and its consideration is vitallyimportant.

4.3 Establishing a new airport in the Thames estuary would require complete redesign of the entireLondon terminal airspace; it is not feasible simply to drop the airspace requirements to support a new airportinto the existing infrastructure. This would potentially constrain other airports in the area. There areadditional considerations in terms of the proximity of neighbouring states and interaction with adjoiningairspace with The Netherlands and Belgium, and the potential eVects on other operations, eg theShoeburyness firing ranges oV the coast near Southend.

October 2008

Supplementary memorandum from Nation Air TraYc Services (NATS) (AIR 29A)

Thank you for the opportunity to present oral evidence to the Transport Select Committee’s inquiry intothe use of airspace on 18 March.

Following that session, we have been asked to provide supplementary evidence to the Committeeregarding whether NATS will make an undertaking to “inform the Committee if it became concerned aboutthe possibility of developments at the European level leading to a dilution in safety standards”.

The highest priority for NATS is safety. Our safety objective is to maintain and improve standards toachieve the highest levels of safety performance. To this end the whole structure and culture of NATS isfocused on safety.

NATS is subject to rigorous safety regulation from the Civil Aviation Authority (CAA). The UK modelof independent safety regulation is increasingly being adopted world-wide in the Air TraYc Management(ATM) industry.

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Internally, we apply a systematic safety management system (SMS) to all operational activities and wereamongst the world’s first Air traYc providers to do so. This formal approach is founded on documentedsafety policies, safety principles and safety procedures. The system forms the basis for risk assessment, safetyassurance, safety control and safety monitoring. The SMS maintains explicit safety standards which complywith national and international obligations. The CAA has oversight of the SMS.

NATS also has a Safety Review Committee (SRC), a Board-level group—supported by independentexperts from safety-related fields—that assists NATS in setting “best in class” safety standards. The role ofthe SRC is to monitor and review the eVectiveness of our safety arrangements and provide advice,independent of the NATS Executive, on improvement where necessary. This Committee is authorised to seekany information it requires from any employee of the company in order to perform its duties.

NATS is also committed to maintaining a “just” culture to encourage the free and honest reporting ofsafety incidents and concerns. The law mandates reporting on certain types and severity of incident. These“Mandatory Occurrence Reports” go straight to the CAA which will, if appropriate, perform an incidentinvestigation independent of the NATS investigation.

External to NATS, the CAA, the UK Airprox Board and the Air Accident Investigation Branch (allindependent of each other) provide a view to Government on the level and standards of safety in NATS.

Given these numerous, formal procedures currently in place and operating with full transparency, we donot believe that introducing a further layer of reporting to the Committee is necessary, nor would it enhancesafety. I would also like to reiterate my comments during the oral evidence session that we do not have anyconcerns regarding safety standards under the existing Single European Sky proposals.

April 2009

Memorandum from the Campaign to Protect Rural England (AIR 30)

Summary

The Campaign to Protect Rural England (CPRE) believes that the present laissez-faire approach to theuse of airspace is unsustainable. Action is required urgently to deal with the flaws in the presentarrangements, which have developed in an uncoordinated manner and are based on outdated evidence.

In particular:

— there is an urgent need for an independent review of the Future of Air Transport White Paper;

— a National Airspace Master Plan is crucial to the eVective use of this national resource;

— ownership of airspace needs to be placed in the hands of a body that is completely independent ofthe National Air TraYc Service (NATS) and the aviation industry;

— current arrangements for planning and regulating the use of UK airspace are reactive andineVective;

— the eVects of aircraft emissions and noise, in particular the costs to communities, are eitherinadequately taken into account or ignored altogether; and

— airport development proposals should be made in the light of their possible consequences on aNational Airspace Master Plan and changes to routes by individual airports should be madesubject to the same Master Plan.

Introduction

1. CPRE welcomes the opportunity to submit evidence to the Transport Select Committee inquiry intothe use of airspace. As a leading environmental NGO with over 62,000 members and supporters, CPRE hasworked to promote and protect the beauty, tranquillity and diversity of rural England by encouraging thesustainable use of land and other natural resources since our formation in 1926.

2. CPRE’s campaigning on the importance of tranquillity in the countryside, and our new tranquillitymaps, has attracted considerable public support. Indeed a significant and increasing proportion of enquiriesfrom members and the general public about our work in this area relate to concern about aviation expansionand change to flight paths.

3. There are important economic and social benefits arising from the promotion and protection oftranquillity as an important aspect of environmental quality. Aviation is increasingly having a detrimentalimpact on tranquil areas popular with visitors, while it contributes to a significant tourism deficit for thecountry as a whole34.

34 CPRE, Aviation—Policy Position Statement, 2008

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Future of Air Transport White Paper

4. The Future of Air Transport White Paper (“the Air White Paper”) forecasts of aviation growth werebased on assumptions which are now grossly incorrect on both the supply and demand sides of the case. Thefollowing factors are of particular relevance:

— the Climate Change Commission’s call for the CO2 reduction target to be increased from 60 to atleast 80%, and in particular the caveat that this target will need to be increased further still if theaviation industry is unable to reduce its emissions by this amount;

— the increase in the price of aviation fuel, the price of which is likely to increase further over the longterm as demand increases in Less Developed Countries;

— the precariousness of many airlines and predictions that more will become bankrupt, which makesprice increases likely rather than continued price cuts;

— the credit crunch and likely impact on future economic growth; and

— a greater understanding of the eVects on health of noise35.

5. Last month, the Sustainable Development Commission (SDC) produced a report entitled ContestedEvidence: the case for an independent review of aviation policy. CPRE gives its unqualified support to theSDC’s call for independent review of aviation policy. Such a review should consider the costs and benefitsto diVerent sections of society36, now and in the future, of diVerent aviation growth and contractionscenarios. We are particularly concerned that a National Policy Statement on Aviation, likely to be producedin 2009 if the Planning Bill is passed, may be based on the Air White Paper. Given the degree of change incontext since it was produced, we believe that this would be perverse and is likely to present seriouschallenges to the work of the proposed Infrastructure Planning Commission and the decision-makingprocess surrounding individual airport proposals.

6. In any event, a re-run of the Department for Transport (DfT) NAPALM/SPASM air traYc forecastingmodel using up-to-date data is imperative before any decisions based on the Air White Paper are taken.

A National Airspace Master Plan

7. In its oral evidence to Sir Joseph Pilling’s independent strategic review into the present and future remitof the Civil Aviation Authority (“the Pilling Review”), CPRE made the point that airspace is an increasinglyscarce national resource but one whose consumption is disordered and unsustainable. We suggested thenthat it is essential both to create a National Airspace Master Plan as well as an independent owner of UKairspace. We suggest that consideration be given to extending the role of the Environment Agency to coverthis. It already has such a role for that other “free” good, rainfall, and strongly promotes demandmanagement for that scarce resource. Extending its role would facilitate bringing the larger airports withinthe remit of the Integrated Pollution Prevention and Control regulations.

8. Both CAA and NATS have already informed DfT that if all the airports in the South-East were toexpand according to the terms of their Master Plans there would not be suYcient airspace to accommodatethe growth, using current or any predicted future airspace management tools and techniques. This is becauseeach airport is currently largely free to grow, in size and in activity level, as it wishes with no regard toadjacent airports or airspace capacity for example. The whole notion of airports, some of which are less than30 miles apart, competing for airline operators and passengers, has led to this chaotic—andunsustainable—state.

9. Allowing consumption of airspace on the basis of a mixture of predict-and-provide and sauve qui peutis folly when it is in such short supply. Airspace Master Plans should also encompass active management ofany capacity changes at each airport, to ensure that the scarce resource is used equitably and to the greatestbenefit of the country as a whole, rather than in support of individual commercial interests.

10. Airspace management considerations should figure prominently in the early stages of any airportdevelopment proposals. It may be that they would be seen by the developer as a delaying factor, but it is anecessary factor to address the present lack of forward planning.

11. Since airspace capacity is a national resource, its consumption should aVord some measure of returnto the exchequer: “slot pricing” as currently implemented appears to be limited to runway slots and returnsmoney to the airport operator. Some form of airspace slot pricing should be considered: this could have thebenefit, for example through making a slot as expensive to consume by a small biz-jet as by a 300-seataircraft, of encouraging eYcient use of the airspace: a form of “airspace pricing” which discourages one slotbeing consumed by flying one small aircraft instead of one large aircraft.

35 Although much more research needs to be done on the impact of aviation noise in tranquil areas: Transport ResearchLaboratory, Aviation, Noise and the Countryside—The Future Development of Air Transport in the United Kingdom, CPRE,2003

36 See for example: CPRE/SERA, Runaway Costs—Social Justice, Environmental Sustainability and the Aviation Industry, 2003

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Effects of Aircraft Noise and Emissions

12. The Pilling Review recommended an urgent updating of the DfT’s Guidance to the CAA onEnvironmental Objectives Relating to the Exercise of its Air Navigation Functions, 2002. The sections of thatGuidance dealing with aircraft noise are based on research, public attitudes and public values dating fromthe 1960s and 1970s. We would therefore strongly support the need for such an update.

13. A proper replacement for DfT’s Attitudes to Noise from Aviation Sources in England (ANASE) studyof 2007 is also urgently required. ANASE produced evidence that was unpalatable for the DfT, showing thatpeople were disturbed at lower noise levels than assumed, and that the current “equivalent noise level” wasnot the most relevant way of measuring and depicting noise exposure. Furthermore, the health impacts ofaviation noise are becoming increasingly apparent although they seem to be ignored in practice. This hasresulted in a significant environmental policy gap which, though it may be advantageous to those keen toexpand aviation, is neither equitable nor appropriate. The DfT’s obvious reluctance to re-work or re-do thestudy is highly regrettable.

14. The claimed “balance” between competing interests, in the case of aircraft noise, is at present far frombeing a defensible one in CPRE’s view. This begins, for example, with noise from civil aviation beingexcluded from the oVence of statutory nuisance in the Environmental Protection Act 1990. The DfT’srepudiation of the evidence from its own ANASE study continues to tilt the balance. A further componentof ANASE was an attempt to ascribe a value (or a cost, depending on one’s viewpoint) to aircraft noisedisturbance. This was also regarded as a failure: so “the balance” in financial terms consists of often-inflatedclaims of economic benefit from the aviation industry as compared with nothing. Balance is not helped,either, by the reluctance by agencies such as DfT to factor-in the down-side of aviation growth in terms ofthe tourism spending deficit—which the OYce for Government Statistics (OGS) states as being over £19billion a year.

15. The aviation industry is a major contributor to climate change. The Greenhouse Gas Emissionsgenerated by aviation are consistently understated, because emissions at higher levels in the atmospherecreate much greater amount of damage than the same quantity emitted at ground level. Currently the onlyemissions which will be “charged” in any way are CO2, and then only as though the emission occurred atground level. Nor is any account taken of the damaging eVects of nitrogen oxides and water vapour injectedat high levels. The whole basis of emissions trading results in aviation being, in eVect, able to buy its wayout of jail and it pays no duty or VAT on the hydrocarbon fuel it burns.

European Airspace Considerations

16. Pan-European management of airspace through the proposal for a Single European Sky or“Eurocontrol” could benefit aircraft and airport operators, passengers and the environment. Clearly asignificant measure of control over national airspace would need to be ceded by the states involved. Therewould also be a need for much more eVective coordination of slot allocations at all European airports.Progress in all of these areas is urgently required but not at the cost of environmental standards being reducedto the lowest common denominator. If Eurocontrol is to become a reality it needs to be based on best practiceenvironmental standards.

Roles and Responsibilities

17. There is a perception outside the aviation industry that a revolving door exists between DfT, CAAand NATS and that the relationships between them are damaging to public confidence in policy making.Decisions over the use of airspace need to be made with a stronger degree of independence. CPRE believesthat a large measure of control over use—as opposed to the technical aspects of route design—needs to beremoved altogether from both CAA and DfT.

Airspace Management Considerations and Planning of Airport Developments

18. Airspace management considerations should always be taken into account in the formulation ofairport development proposals. Whether those considerations cause delay to the proposals is largely in thehands of the proposers: if proposals are made at the appropriate time and with suYcient precision there isno prima facie reason why delay should occur.

19. Unlike any other industry, the eVects of changes in aviation operations, in particular with respect tonoise pollution and visual intrusion, can suddenly be spread over tens or hundreds of thousands of people.Transparency, early consultation and consultation that is really meaningful in the sense that its results,however unpalatable, are acted on, are urgently required. The examples of the airspace changes for WestEnd in 2006 and Terminal Control South West in 2008 demonstrate how reasonable objections from CPREand others were eVectively ignored in the decision-making process. The latter changes are now subject tojudicial review.

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Transport Committee: Evidence Ev 185

Other Users of Airspace

20. Airspace, particularly in the South East, is at a premium. It has to be the case therefore that the subjectof priorities for consumption of airspace must be examined, ideally on the basis of “greatest good to greatestnumber”, which might be taken as “greatest overall proven economic benefit”. If an “eYcient use ofresources” approach were to be taken in respect of airspace there would, and should, undoubtedly be adverseconsequences on recreational flying: and any other form of “general aviation” such as “bizjets” whichconsume airspace capacity in a demonstrably sub-optimal way. This will be a diYcult issue to address: thereare recreational flying facilities which have existed for a long time and which, under present rules, are treatedequally with all other consumers of airspace and are able to take the line “what we have, we hold”. Thoughthe consequences for fly-for-fun airfields, for example, would be painful such an approach appears to beinconsistent with eYcient use of airspace.

Resourcing of Airspace Changes

21. Currently NATS, majority-owned by airlines, airports and its staV, carries out this work using its ownstaV, and derives comfortable levels of income and profit through raising navigation charges from“consumers” of airspace. NATS’ charging and profit levels are, one understands, regulated by CAA underthe terms of NATS’ licence. This seems a relatively equitable way of proceeding and in line with the termsif its licence which requires it to “meet any reasonable level of overall demand”. If the level of demand isdeemed to be unreasonable, whether through environmental constraints, lack of airspace capacity or trainedpersonnel, it should be for the CAA to so declare, provided it has been given clear environmental guidanceby Government.

22. NATS navigation charges are set to generate a commercial rate of return from its operations, andthese fall on the consumers of airspace (airlines) which in turn recover these and other costs from the enduser (the passenger). This appears to be an eVective mechanism: save for the lack of any return to thepopulation as whole, which should be regarded as the owner of the airspace.

23. It could be claimed by NATS that some consumers of airspace, particularly those engaging inrecreational flying, are in eVect getting a “free ride” since they derive benefit from the existence of theuncontrolled airspace in which they are free to fly but which can only exist because NATS has defined, andmanages, areas of controlled airspace. The relative proportion is small, however, compared with commercialaviation and could therefore be ignored though that proportion may need to be assessed periodically toensure that it remains negligible.

Recommendations

24. There is much that is wrong with the way in which airspace is currently allocated, used and managed.CPRE hopes that the Transport Select Committee will carefully consider the views expressed above informing its conclusions as to appropriate ways forward. In particular, we ask that the Committeerecommend that:

1) There should be an independent review of the Air White Paper;

2) A National Airspace Master Plan is promoted by Government;

3) Ownership of airspace is given to an independent body;

4) A pricing mechanism is introduced to allocate airspace eYciently;

5) The Pilling Review recommendations on providing the CAA with a stronger environmental remitare implemented as soon as possible;

6) There is much faster implementation of Eurocontrol, with environmental standards raised to “bestpractice” levels; and

7) The securing airspace is made a pre-requisite for any airport development proposal.

October 2008

Supplementary memorandum from Campaign to Protect Rural England (AIR 30A)

I would like to thank you on behalf of my colleague Michael Nidd and my own behalf for your invitationto CPRE to give evidence to the Transport Committee last month. Whilst giving our evidence, we oVeredto supply the Committee with further information, which I do in this letter.

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Ev 186 Transport Committee: Evidence

Night Noise from Airports

I attach a note on the production of eight-hour night noise contours for UK airports. CPRE believes thatall UK airports should produce annual night contours or should have their night movements regulatedaccording to the principles adopted for the three principal London airports (Heathrow, Gatwick andStansted). We hope that the Committee will feel able to make a recommendation on the subject.

Tranquillity

It was not possible in the time available to give the Committee a proper insight into the work done byCPRE to map tranquillity in England. However, we would wish to clarify and further explain some of thepoints made in oral evidence. We attach a brief note about the methodology used to generate the nationaltranquillity maps. We would like to stress that this methodology combines objective data from national datasets such as from the Ordnance Survey with subjective weighing of 44 potential factors, based on statisticallysignificant public consultation. The subjective element was necessary to weigh the importance of diVerentincommensurable factors, such as frequency of air traYc movements, decibel levels and electricity pylons,which cannot be compared using objective factors.

It is important to emphasise that any analysis of human sensory responses to environmental factors is bydefinition subjective, as people are by their nature sentient individuals. The cumulative weight of a largesurvey (more than 3,000 objectively recorded responses) gives statistical importance to the data.

My colleagues also stand ready to provide whatever further information would be of assistance, and tomeet all or any members of the Committee to give additional information or explanations. I hope that theCommittee will find that the tranquillity mapping is a helpful tool in establishing the likely consequences ofpolicy decisions.

Integrated Planning

The Committee asked us whether we were in favour of integrated planning for airspace and land use. Wefavour this without reservation. We also favour integrated airspace planning, such as by including a nationalairspace masterplan within a National Policy Statement on Aviation, and believe that it should be theresponsibility of a single body. We believe that both the CAA and NATS would support such an approach.When they gave joint evidence to the Competition Commission in May 2007, they said:

“CAA and NATS are of the view that, were all of the south-east’s airport development plans tocome to fruition, there would not be suYcient airspace capacity to accommodate the scale of thepredicted traYc growth on the basis of current and predicted technology.”

The further strengthens our view that no planning application to increase the throughput of a particularairport should be undertaken until it has been objectively demonstrated that the requisite airspace isgenuinely available, and that safety is not compromised.

It also underpins the need for a single body to be responsible for planning both airport growth andairspace utilisation. It seems to us that neither the CAA nor NATS regard themselves, severally or jointly,as the bodies to do it.

We would be pleased to give any further explanations or information that might be helpful to theCommittee.

Noise Contours

Noise contours around airports provide a systematic basis for monitoring and, where necessary, tacticalcontrol of the noise disturbance created by airport operations. For many years the CAA has requiredairports to produce 16-hour day A-weighted noise contours (in acoustics shorthand, LAeq,16h), based onthe busiest 92-day period in the year. The CAA defines “day” as extending from 07.00 until 23.00.

No Requirement for Night

No similar contours (LAeq,8h) have been universally required to cover the complementary night period(from 23.01 until 06.59). Thus there is no generally-applicable method for monitoring and control of nightnoise, though a small number of airports do have schemes of one form or another.

Airports Producing Night Noise Contours Occasionally

BAA’s London Area Airports (Heathrow, Stansted and Gatwick) do not routinely produce night noisecontours, but have, from time to time, produced such contours as part of planning applications, as haveBristol, Liverpool and Birmingham. Nevertheless, night noise disturbance caused by those airports ismanaged through a DfT scheme based on numbers of aircraft movements and the total “quota units”.

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Airports Producing Night Noise Contours Regularly

East Midlands, Luton and Manchester Airports produce LAeq,8h night noise contours annually as aresult of conditions attached to planning permissions.

The Environmental Noise (England) Regulations 2006, which stemmed from the EU Directive onEnvironmental Noise (EC 2002/49), have required Airports which support more than 50,000 air transportmovements a year to produce night contours. These are broadly similar to LAeq,8h contours, although thecontour intervals are spaced diVerently from those adopted by the CAA. These were produced for most busyAirports for 2006, and that process should be repeated in five years’ time. We attach a list of the airportsinvolved in the 2006 exercise. Thus these night noise contours, though instructive from a strategic, land-useplanning viewpoint, are not suitable for the tactical control of night noise because the five-year update cycleis too infrequent.

Airports Producing Noise Maps in 2006

1. Birmingham International Airport (EGBB)

2. Blackpool Squire’s Gate Airport (EGNH)

3. Bournemouth Airport (EGHH)

4. Bristol Lulsgate Airport (EGGD)

5. Coventry Airport (EGBE)

6. Leeds Bradford Airport (EGNM)

7. Liverpool John Lennon Airport (EGGP)

8. London City Airport (EGLC)

9. London Gatwick Airport (EGKK)

10. London Heathrow Airport (EGLL)

11. London Luton Airport (EGGW)

12. London Stansted Airport (EGSS)

13. Manchester International Airport (EGCC)

14. Newcastle International Airport (EGNT)

15. Nottingham East Midlands Airport (EGNX)

16. Shoreham Airport (EGKA) (daytime only)

17. Southampton Eastleigh Airport (EGHI)

18. Southend Airport (EGMC)

March 2009

Supplementary memorandum from Campaign to Protect Rural England (AIR 30B)

NOTE ON TRANQUILLITY METHODOLOGY

The concept of mapping all undisturbed countryside as a resource in itself—tranquillity mapping—derives from groundbreaking work by Simon Rendel of ASH Consulting in a study for the Department ofTransport in 1991. ASH Consulting produced a set of highly influential national and regional Tranquil Areamaps for CPRE and the Countryside Commission published in 1995. In these maps, “Tranquil Areas” weredefined as “‘places which are suYciently far away from the visual or noise intrusion of development or traYcto be considered unspoilt by urban influences”.

In 2004 CPRE, supported by the Countryside Agency (now Natural England), commissionedNorthumbria University and the University of Newcastle-upon-Tyne to carry out a pilot study to developa methodology to map tranquillity in two pilot areas. This study developed the tranquil areas work through:

— extensive public and stakeholder consultation with over 430 people using participatory appraisal(PA) to define what factors contribute to and detract from tranquillity (positive and negativefactors);

— accounting for the presence of positive features or factors which can foster tranquillity;

— reflecting the cumulative impact of positive and negative factors in a given area;

— more advanced modelling techniques with GIS (Geographic Information Systems) to reflectdiVusion of factors over distance; and

— production of detailed continuous surface maps of tranquillity on a relative scale from lowest tohighest.

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Ev 188 Transport Committee: Evidence

Further PA work carried out in the Chilterns AONB in 2004 with over 580 participants confirmed thegeneral transferability of the consultation approach with further methodological developments. Thisprovided a firm basis for the use of these findings to map tranquillity at a national scale.

In 2006 CPRE commissioned a project to map tranquillity on a national scale which drew extensively onthe earlier work in 2004. The approach adopted combines two main streams of data collection andintegration:

1. Public consultation

Over 1,300 people were surveyed in 20 separate locations across England to rank and quantify thepositive or negative factors on a national basis; participants were asked to select three positive andthree negative characteristics that most contributed to or detracted from an experience oftranquillity. The number of responses for each of the 44 option choices (21 positive, 23 negative)was converted into a percentage which provided a way of weighting each option choice in orderof relevance.

2. A GIS (Geographic Information System) model to map tranquillity

GIS was used to provide a spatial footprint of the 44 option choices. In the national model thesewere divided into two key themes—“what you can see” and “what you hear”—to make the linkbetween digital datasets and the ability to model “visibility” and “noise” clearer. Data wascompiled separately for both positive and negative option choices and was derived from existingnational datasets compiled by relevant competent authorities. Raw data for each factor werereclassified on a scale from zero to ten to establish parity between widely varying types of data.Ten represents the strongest and zero the least contribution to or detraction from tranquillity.Reclassified data were then weighted according to the consultation results and combined intonegative and positive totals. Scores for negative tranquillity were taken away from scores forpositive factors to give an overall score for how “tranquil” a given 500m by 500m cell will be onthe relative national scale.

March 2009

Memorandum from London City Airport (AIR 31)

1. Introduction

This response to the House of Commons Transport Committee’s invitation to submit evidence on itsInquiry into the use of airspace is submitted by London City Airport (LCY). London City Airport is ownedby Global Infrastructure Partners (GIP).

2. Summary

See bullet points in attached LCY paper.

3. Responses

“What changes to the management of airspace could be required as a result of the additional airport capacityoutlined in the 2003 White Paper? Are the White Paper’s projections for increased passenger demand stillaccurate? Are all the measures to provide increased passenger demand likely to be implemented?”

3.1 LCY continues to believe that the forecast overall increases in passenger demand over the period to2030 as presented in the 2003 White Paper are broadly valid despite current economic circumstances whichare likely to have a short term negative impact. We believe that these forecasts are reflected in thedevelopment of airport capacity to meet that demand.

3.2 The 2003 White Paper notes that the additional airport capacity required to meet forecast demand“must be matched by a corresponding increase in airspace capacity”. However, despite the White Paper’saims for a structured programme for the redesign of UK airspace being brought forward by the CAA therehas so far been little obvious movement towards this objective. The development of airspace appears to beprogressed on a somewhat piecemeal basis. The committee’s inquiry is therefore timely.

“Can safety be maintained as airspace is increasingly utilised? Is there suitable interface between military andcivilian arrangements for air traYc control?”

3.3 Safety within aviation has to be maintained at the highest possible levels and LCY is confident thatthe exceptional record of all of the stakeholders in the UK aviation industry ensures that these highstandards are maintained and enhanced as time progresses and traYc increases.

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3.4 At the operational level there is an eVective interface between military and civilian air traYc control.However, we do not consider that this interface is necessarily maintained at the strategic level, particularlyin relation to “ownership” of airspace and any strategic initiatives to facilitate the release of military airspacefor civilian use. If such airspace could be released on a permanent basis, it would enable civilian flights tomake use of that additional capacity and potentially facilitate more direct routings, which would haveenvironmental and economic benefits through reduced fuel burn.

3.5 The Committee will be aware that the military does allow short term release of some of its airspaceeg at weekends. However, these short term fixes, whilst useful, do not provide the long term airspace capacitygains that would be greatly welcomed by commercial aviation. Weekends tend to have the lowest proportionof business travellers.

3.6 An issue which is very important to UK airports and air navigation service providers (ANSP) is thefuture supply of qualified air traYc control oYcers. This could have serious repercussions for the futuredevelopment of UK aviation as a whole if it is not addressed. One useful constituent to an overall approachto this issue would be a review of the current lengthy and expensive conversion arrangements required formilitary controllers to become controllers in the civil sector.

“Is the current approach to planning and regulating the use of airspace adequate? Would an Airspace MasterPlan covering the period of the White Paper be beneficial? Could a piecemeal approach to individualdevelopments necessitate additional redesigns subsequently?”

3.7 The responsibility for planning and regulating airspace lies with the Civil Aviation Authority andmore specifically its Directorate of Airspace Policy (DAP). While we believe that DAP is an eVectiveregulator we also believe that there is relatively little evidence of it developing the inclusive “structuredprogramme for the redesign of UK airspace” as envisaged by the 2003 White Paper.

3.8 LCY fully supports the development of a UK Airspace Master Plan covering the period of the WhitePaper and beyond. Such a Master Plan could complement the work being undertaken in Europe on theSESAR initiative (covered in more detail in paragraphs 3.16 to 3.24 inclusive). A Master Plan would providea structured framework within which airspace development could be progressed and implemented and(following wide consultation) with a presumption in favour of such developments.

“How are the eVects of aircraft noise and emissions taken into account when changes are made to the use ofairspace? Who should be consulted about such changes? How should the balance between conflicting interestsbe struck?”

3.9 Airspace change proposals are supported by a CAA document, CAP 725 Airspace Change ProcessGuidance. This document was initially published in 2002 but has been updated as since that time “publicinterest in aviation-related environmental matters has greatly increased, in part prompted by theGovernment’s Air Transport White Paper published in December 2003. At local level, noise and emissionshave emerged as significant issues . . .”.37 Accordingly, environmental considerations play a key part in anyproposal to change airspace.

3.10 Appendix B to CAP 725, Airspace Change Proposals—Environmental Requirements states:

“The Civil Aviation Authority (Air Navigation) Directions 2001 (incorporating VariationDirection 2004) (HMG, 2001) requires the CAA to take into account “the need to reduce, controland mitigate as far as possible the environmental impacts of civil aircraft operations, an inparticular the annoyance and disturbance caused to the general public arising from aircraft noiseand vibration, and emissions from aircraft engines”. And “It is the function of this document toassist those preparing airspace change proposals in providing suYcient environmental informationfor public consultation and to inform the decision making process”.

3.11 CAP 725 requires airspace change proposals to be supported by:

— A description of the airspace change;

— TraYc forecasts;

— An assessment of the eVect on noise;

— An assessment of the change in fuel burn / CO2;

— An assessment of the eVect on local air quality;

— An economic valuation of environmental impact.

3.12 In terms of public consultation, CAP 725 requires the proposer of the airspace change to identify“all of the diVerent parties aVected by the design options”38 and to have undertaken a stakeholder analysisto ensure that it can be demonstrated that a complete consultation on the proposal has taken palace.

37 CAP 725 CAA Guidance on the Application of the Airspace Change Process—Foreword.38 CAP 725 CAA Guidance on the Application of the Airspace Change Process, Page7, Paragraph 14.

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Ev 190 Transport Committee: Evidence

3.13 Regarding the balancing of conflicting interests, CAP 725 states:

Consensus is not necessary nor should it be expected. However, a Change Sponsor will beaccountable for their decisions to either accommodate or disregard consultees’ responses and forproviding timely feedback to the consultees. These decisions will be scrutinised and form part ofthe Directorate’s (DAP’s) assessment criteria at the Regulatory Decision stage.

3.14 LCY considers that CAP 725 provides comprehensive and proper provisions in relation toenvironmental issues arising from proposals to introduce airspace changes and to take account of the viewsof the general public and other stakeholders in the proposal consultation process.

3.15 However LCY believes that CAP 725 would be more eVective if it was accompanied by a UK wideairspace master plan, championed by the CAA.

“How does the management of airspace in the rest of Europe aVect flights into the UK? Is there an opportunityto integrate our plans for changes to airspace management more eVectively with those of other EuropeanCountries?”

3.16 It is widely acknowledged that airspace over Europe is highly fragmented having developed largelyaround State borders. This fragmentation does not provide for a high level of air traYc management (ATM)eYciency and until it is fully addressed the system will become more congested as traYc continues to grow.

3.17 As a direct result of the need to completely reconsider how European ATM will deal with the futuredemands for sustainable growth in air transport, the SESAR (Single European Sky ATM Research)initiative was introduced. For the first time in European ATM history an ATM improvement programmeinvolving all of the aviation stakeholders ( civil and military users, ANSPs, airports, aerospacemanufacturing, regulators and legislators) has been launched with the objective of achieving a “paradigmshift” through a pan-European approach to the planning and delivery of European ATM and in support ofSingle European Sky legislation. LCY supports this initiative.

3.18 The first phase of the SESAR project was completed in March 2008 with the production of a Europewide ATM Master Plan which will form the basis of the project’s next phase, the Development Phase, to becompleted by 2013. The intention is that this ATM Master Plan will be a living document updated asprogress is made.

3.19 SESAR is the only pan-European ATM development programme and it will only succeed indelivering its objectives through the commitment of all of the ATM stakeholders. To date the CAA, NATS,DfT, UK airports and some airlines have been directly involved.

3.20 A UK wide Airspace Master Plan would neatly dovetail into the SESAR ATM Master Plan.

3.21 The SESAR objectives are extremely challenging:

— A three fold increase in capacity which will reduce delays both on the ground and in the air.

— Improve safety performance by a factor of 10.

— A 10% reduction in the eVect that flights have on the environment.

— A reduction of at least 50% in the cost of providing ATM services to airspace users.

“What opportunities are there to apply new techniques and technologies to reduce wasteful flying on indirectroutes and excessive “stacking” while planes wait to land? How can the potential of any such opportunities bestbe realised? Could environmental benefits be gained as a result of such improvements?”

3.22 Fundamental to the success of SESAR is the development and application of new technologies andtechniques and as such a huge eVort is going into the necessary research and development that will enablethese factors to be delivered. Associated with many of these applications is the need to deliver quantifiableenvironmental improvements in all phases of flight.

3.23 The aviation industry is however not sitting back and waiting for SESAR to make things happen.New air traYc control techniques including Continuous Descent Approach (CDA) are being introduced atsome airports which deliver benefits including reduced noise, less disturbance to local residents and lowerfuel burn. In addition, airports generally are highly pro-active in promoting and delivering environmentalmitigation and improvement schemes, many in consultation with their community stakeholders. This is aparticular feature at LCY an inner city airport.

3.24 The work undertaken in SESAR is already starting to demonstrate how new ATM techniques andarrangements may provide benefits. Initiatives such as Collaborative Decision Making (CDM) will delivereYciency gains by improving the processes whereby airport, ANSPs and airspace users interact and therebydeliver environmental benefits through less unnecessary fuel burn both on the ground eg by more eVectivetaxiing; and in the air through more direct routings and sequenced operations that reduce the need to“stack”.

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3.25 The flexible use of airspace will also enable capacity gains to be achieved as will the use of militaryairspace. Furthermore, the development of Functional Airspace Blocks (FABs) between neighbouringStates will reduce the fragmentation of airspace over Europe and deliver improved ATM eYciency.

“In relation to the redesign of UK airspace of the roles and responsibilities of each of the interested parties—Department for Transport, the CAA, airport operators, NATS, etc—appropriate and clearly understood? Arethe structures of the parties appropriate for undertaking the roles that they should play?

3.26 LCY has some concern that the roles and responsibilities for airspace redesign are not particularlywell defined or understood. The role of DAP is undeniably that of a regulator but it is not clear that DAPis undertaking the function of a strategic planner of airspace as envisaged by the Government in the 2003White Paper.

3.27 LCY considers that the overall process for airspace capacity and planning does not work as well asit could. It is largely piecemeal, is protracted in terms of process, and creates diYculties for airports inachieving local authority planning approval for development plans.

“Do airspace management considerations delay the planning processes in relation to airport developmentproposals? How will airspace management considerations be taken into account by the proposed newInfrastructure Planning Commission and the relevant National Policy Statements on airport planning?”

3.28 Airspace management impacts airport capacity development proposals. LCY believes that in futureis possible that an airport’s development plans may include and, to some degree, be dependent upon,changes to its airspace, and that this should be scrutinised by local planning authorities when applicationsto develop capacity are submitted.

3.29 LCY is not aware of how airspace considerations will be taken into account by National PolicyStatements on airport planning. What is required is a National Policy Statement on airspace and an AirspaceMaster Plan, against which airport development plans could be tested by local planning authorities.

“What could be the implications for smaller airfields, recreational flying and helicopters of changes to airspacemanagement to enable safe and eYcient increases at the UK’s major airports? How should an appropriatebalance between conflicting priorities be determined?

3.30 It is undeniable that changes to airspace management to enable capacity gains at major airports couldimpact upon the stakeholders referred to in this question. However, as stated above (paragraphs 3.9 to 3.15inclusive) CAP 725 provides a comprehensive framework for consideration of such airspace changes andallows for all stakeholders and parties aVected by the proposed changes to be fully consulted. This CAP alsoincludes appropriate provisions whereby conflicting priorities can be addressed.

“Will it be possible to recruit and train staV in order that airspace changes can be implemented in parallel withadditional airport capacity”

3.31 This question has two basic components ie airspace design and air traYc control management.

3.32 In terms of airspace design, there appears to be a shortage of qualified designers in the market withthe primary resource coming from individuals who were once employed by DAP when it used to provide anairspace design service. Whilst there is little evidence that this level of approved design supply is causingcurrent problems this situation may worsen over time.

3.33 Once changes have been approved they have to be implemented and this is where the requirementfor air traYc control staV to manage the revised airspace comes into play. As previously stated, there is acritical forecast shortage in the supply of qualified air traYc control oYcers and while automation and newtechnologies may address some of this anticipated shortfall there remains a clear need to find means wherebysupply can match demand. This will involve additional training resources and initiatives such as making thetransition from military to civilian air traYc control more streamlined.

“Who should fund airspace changes? Is there likely to be enough funding to undertake the redesign required tobring about the necessary additional airspace capacity?”

3.34 LCY believes that the responsibility and funding for the development of a structured programme forthe redesign of UK airspace as proposed in the 2003 White Paper should lie with Government. Whileexecution of this process would lie with CAA the costs should not be included in CAA’s charges to airspaceusers and airports.

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SUPPLEMENTARY COMMENTS SUBMITTED BY LONDON CITY AIRPORT LTD

1. The comments below should be considered in conjunction with the London City Airport (LCY)responses to the Transport Committee Questions. LCY welcomes the committees focus on airspace issuesin light of the Government’s decision to review future airport strategy.

2. LCY is owned by Global Infrastructure Partners (GIP) and handled 3.2 million passengers and 90kaircraft movements in the year to 30th September 2008.

3. LCY has recently been granted approval by the London Borough of Newham (the local planningauthority) to increase permitted aircraft movements to 120k p.a.

4. Ultimately LCY may be capable of handing at least 170k p.a aircraft movements on the ground. Howthis might be achieved is detailed in the LCY Master Plan published in 2006 in response to the 2003 WhitePaper—The Future of Air Transport. This Master Plan can be accessed via our website(www.londoncityairport.com) and a hard copy is attached. Further copies can be made available to thecommittee should you wish.

5. LCY growth to 170k or more movements a year is only achievable if there is suYcient airspace to copewith this demand, at a time when other airports will also be seeking increases in airspace capacity.

6. LCY considers that there is currently a shortage of airspace capacity in London and the South East.This shortage manifests itself in delays to aircraft both in the air and on the ground. LCY welcomes theproposed TC North airspace re-design currently being consulted on by NATS.

7. LCY believes this shortage should be addressed by Government, CAA and NATS as a matter ofurgency due to the potentially negative impact this has on the regional economy, and London’s role as amajor world city.

8. An initial view would suggest that we are always likely to have, or be close to, a shortage of airspacecapacity in London and the South East. This suggests that some form of organised priority action ofcapacity is likely to be required.

9. LCY has commissioned research to test the economic impacts of diVering types of passengers andaircraft. LCY believes some passenger to be significantly more beneficial to UK plc than others. Anyprioritisation of airspace capacity should we believe take full account of the economic significance ofdiVering types of passengers.

10. LCY would be happy to share this research with the committee and discuss the conclusions wehave reached.

11. In essence our comments can be distilled into the following bullet points:

(a) There is a current shortage of airspace capacity which will inhibit the delivery of the UK airportcapacities envisaged in the 2003 White Paper.

(b) The UK needs an airspace capacity Master Plan to integrate with the Air Transport White Paperand SESAR.

(c) A form of long term capacity rationing is required to deal with current demand levels, as (b) abovemay take a decade or more to prepare and consult about.

(d) Prioritisation of capacity involving discrimination in favour of those airports, aircraft andpassengers that are demonstrably of more economic value to UK plc makes the most eYcient useof airspace.

(e) Supply of suYcient air traYc controllers and airspace designers is vital in providing future airspacecapacity increase.

October 2008

Memorandum from British Airways plc (AIR 32)

Introduction

British Airways (BA) welcomes the opportunity to submit evidence to the Transport Select Committee’sinquiry into “The Use of Airspace”.

The airline’s main base is London Heathrow Airport, the UK’s primary international hub airport andone of the busiest airports in the world. BA also operates from 9 other airports in the UK, and worldwide,to 154 destinations in 75 countries. It employs more than 43,000 people, of whom 38,000 work in the UnitedKingdom.

BA oVers almost 550 flights in total to and from Heathrow each weekday, with a further 190 services aday to and from London Gatwick daily and 44 per day to and from London City.

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BA Response to Specific Questions as set out in the Terms of Reference

1. What changes to the management of airspace could be required as a result of the additional airport capacityoutlined in the 2003 White Paper?ii) Are the White Paper’s projections for increased passenger demand still accurate?iii) Are all the measures to provide for increased passenger demand likely to be implemented?

BA believes there is a need for planned restructuring of UK airspace to accommodate new runways,general increases in capacity, to accommodate more flights and to reduce delays and unnecessary emissions.There is also a need for clarity about how strategic airspace change is to be taken forward reflecting thedecisions taken in 2003 Air Transport White Paper (ATWP). This is urgent for SE England where two newrunways are planned to operate within the next 10 years or so, in addition to more immediate changes inairspace management to make better use of existing capacity.

It is long overdue to have a master plan in place to deal with development and changes of this complexityand strategic significance.

Heathrow is the most important airport in the UK and SE England. This must be recognised by NATSwhen strategically planning increases to airspace capacity, but also in their day-to-day management of airtraYc flow. BA has evidence suggesting LHR is unfairly discriminated against in day-to-day managementof airspace, which may be because it is easier to place a restriction on LHR alone to take a proportion ofdemand from the system, rather than place several smaller restrictions across the SE airport network. Thismeans LHR sees poorest performance, when it is least able to absorb consequences due to lack of capacityfor resilience.

ii) We agree that 2003 ATWP projections of increased passenger demand remain reasonable assessmentsfor long term planning analysis for additional airport capacity. However, we believe projections of sustainedpeak-period demand from air traYc movements (ie number of flights) are more important than rawpassenger numbers in assessing need for expanding runway and airspace capacity. Airspace capacity needsto match runway capacity, and it is actual numbers of movements that create airspace workload.

iii) In due course we expect all ATWP measures providing increased capacity at Heathrow will be needed;indeed they are overdue. They are also capable of being implemented. We fully expect environmentalconditions to be met, and our fleet purchases are designed to contribute to that. BA’s concern is that plansare developed and implemented to change the airspace that serves flights to Heathrow in particular, and theUK generally, in a timely way so airspace improvements are not on the critical path inhibiting capacitygrowth, delay reduction and avoidance of unnecessary emissions due to congestion. We have focused ourwork on the centrepiece of the ATWP for the national economy, the expansion of Heathrow. We do not oVerspecific evidence on other ATWP-endorsed airport developments.

2. Can safety be maintained as airspace is increasingly utilised?ii) Is there a suitable interface between military and civilian arrangements for air traYc control?

i) Safety both on the ground and in air is paramount; we would not proceed if we believed safety couldnot be guaranteed. In fact, improving technology oVers technological and management improvements onthe plane and the ground both of which facilitate increasing capacity and improving safety margins. ThePan-European Single European Sky II (SES II) and SESAR (Single European Sky ATM Research)initiatives oVer opportunities for introducing wide reaching changes to technology and organisation ofairspace with clear benefits in structural and fuel eYciencies, extra capacity, reduced emissions and improvedsafety. SES and SESAR initiatives need full UK backing in order to realize their benefits.

ii) We recognise the importance of Military use of airspace, however our perception is that more airspacecould be freed in terms of geography and time windows of use to ease pressure on the commercial ATCenvironment. There is interface with the Military in the UK, but could be improved. We are seeing somegood interfaces between NATs and Military, in particular at Swanwick where they share a joint cell. Thishas resulted in some significant improvements to flexibility of some military zones, eg the PortsmouthDanger areas use being modified to assist NATS. However, the key remaining issue is that there is still toomuch airspace dedicated to military use, and there seems a lack of positive momentum to move this further.We welcome any joint working to reinvigorate resolution of this issue.

Apart from UK Military, we observe a clear impact on UK ATC of Foreign Military. In particular UKaviation is highly impacted as a result of foreign military danger areas eg in DOVER sector, CBA1 zoneunder French Military control. This area causes frequent disruption and rerouting around one of the busiestareas of airspace between UK and Europe. As an example, this area alone is regularly observed to accountfor 5–8% of UK delays.

We also need to recognise LHR has intensely used airspace with restricted capacity and its operations andpassengers are all too often disrupted by adhoc users, fly-pasts and helicopter transfers. The US presidentialvisit to LHR directly aVected the operation of the airport across three days and was felt by the airlinecommunity to be unreasonable given number of passengers badly and unnecessarily aVected and the

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Ev 194 Transport Committee: Evidence

significant cost borne by airlines. Our research has shown that for BA alone, 53 flights were cancelled-impacting 4,887 passengers, 264 flights were delayed more than 30 minutes and in total over 33,000passengers were delayed 30 minutes or more.

We recognise the need for occasional adhoc non-civil activity, but given the economic importance ofHeathrow and constraints on the airports ability to absorb delay, we recommend the approvals process forsuch activity include a full risk and disruption analysis with input from the airline community and airport,including analysis to define suitable alternative Military airfields able to host such activity.

3. Is the current approach to planning and regulating the use of UK airspace adequate?ii) Would an Airspace Master Plan covering the period of the White Paper be beneficial?iii) Could a piecemeal approach to individual developments necessitate additional redesigns subsequently?

BA considers the current approach to planning UK airspace is inadequate and lagging behind in termsof what is needed to implement the overdue major airport expansion projects in the ATWP. The ATWP wasissued five years ago, and yet there is still to be an Airspace Masterplan published. The ATWP was explicitin terms of the Government’s commissioning the Civil Aviation Authority to produce such a plan39.

In the view of BA there is scant evidence to date of progress by the CAA in meeting this explicit remitfrom Government. The exploration by the committee of this fundamental failure, and how to rectify it is,in BA’s view, important so that essential progress in this area of national infrastructure planning can bekick started.

In terms of regulation of UK airspace, the regulation is fragmented and as a result, not eVective across UKairspace as a whole—NSL (NATS Service Ltd) and NERL (NATS Enroute Ltd). There is clearly definedregulation on NERL, and as a result, there is clear and demonstrable progress within their accountabilitiesin reducing delays, improving investment and performance.

However NSL does not fall under this regulatory structure, despite for practical purposes operating anumber of noncontestable local airport monopolies, at least at the busy southeast England airports. Thismeans the local airspace delays in landing and departing from airports are not currently included in theregulatory review, and not subject to quality and delay targets set.

In addition, there is inadequate inter-agency transparency and uncertainty between NSL and NERL overresponsibility for some aspects of poor delay performance. As a minimum this needs addressing in the licenseconditions of NERL. More importantly, in BA’s view the regulatory process should be extended to includeNSL operations at airports where the changing the provider of air traYc services is practically impossible.In BA’s view these weaknesses contribute significantly to the level of performance on airspace delays atairports like Heathrow, where there can be excessive holding on waiting to land. These airspace delays localto Heathrow do form a significant proportion of Heathrow delays as demonstrated by the CAAcommissioned LHR/LGW runway resilience study. Economic regulation of NSL at airports in the southeast(or elsewhere in the UK where provision of airport ATC services is eVectively non-contestable) is needed toincrease performance and resilience and ensure airspace is managed eYciently as a whole.

ii) Yes, airspace Master planning covering the period of the ATWP would be beneficial. BA fully supportsimplementation of the government approach of having a long-term master plan for airport development. Itis imperative in achieving timely airport expansion, where coordination amongst (inter alia) airports, airspace providers, airlines, economic and environmental regulators, surface access providers, local andnational government is required. Heathrow in particular is the UK’s global hub and it is extremely importantthat airspace improvements are not on the critical path for capacity growth. At the present time, BA sees agreat risk that airspace restructuring will be the item that holds up achievement of necessary airspace andairport capacity expansion. Airspace development needs to be handled in an integrated manner alongsideairport expansion.

iii) Yes, we see a piece meal approach as a considerable risk to making progress with key developments.That is why we are seeking an integrated master plan that can be implemented sequentially without requiringlater redesign. BA has a considerable concern that the current Airspace change process as it stands, haspotential for open-ended reiterations. We do not know if the recent consultation on NATS Terminal ControlNorth is a sound start, as we have no overall Masterplan airspace plan within which to assess it. There needsto be a way of drawing it to a timely conclusion. In our view the first issue to be tackled is the need for anairspace master plan. At this time, we understand conversations have been taking place but no clear planor strategy has been made visible. DAP, DfT and NATS are all involved but no one appears to be takingthe lead in producing or coordinating the plan. BA believes that due to the strategic importance of the issue,if there is any ambiguity about the CAA’s mandate and accountability for taking a lead as the DfT taskedthem to do in the 2003 ATWP, then that ambiguity should be removed.

39 The Civil Aviation Authority is responsible for the planning and regulation of UK airspace. The Authority has examinedproposals for additional airport capacity contained in this White Paper. It believes that the necessary airspace capacity can,in broad terms, be provided safely through the redesign of airspace and the introduction of enhanced air traYc techniquesand systems. The Government will now look to the CAA to make early progress in bringing forward a structured programmefor redesign of UK airspace, with a view to phased implementation of changes to eliminate constraints and permit theintegration of the forecast increases in aircraft movements, including traYc using the additional runways proposed in thisWhite Paper. (The Future of Air Transport White Paper 2003, page 145, para 12.26

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4. How are the eVects of aircraft noise and emissions taken into account when changes are made to the use ofairspace?ii) Who should be consulted about such changes?iii) How should the balance between conflicting interests be struck?

i) The explanation of the process used for taking the eVects of noise and emissions into account is aquestion for those who take the decision based on the analysis, rather than an airline.

ii) There is a degree of obscurity on the consultation process, depending on who is to make the decisionand who has requested the change. We would view it is as a role for DAP acting on the information providedby the proposer of the change. For example with the TC North consultation: Airlines and Localcommunities should be involved but there must be a cut oV point in consultation to avoid endlessreiterations.

iii) In the case of strategic changes to airspace the decisions by DAP need to be made within the contextof the government having taken strategic decisions on airport capacity, which took into account airspacechanges in broad terms. That will ensure that the airspace implications of national policy decisions onairports’ expansion can realistically be implemented having already been through an extensive democraticprocess over several years that led to the ATWP decisions. Subsequently the step-by-step part ofconsultation should take into account the detailed local views of stakeholders during each aspect of theimplementation. These judgements need to be made taking the views of all stakeholders and thecircumstances of each change. It is important that the CAA has a clearly defined remit to make thesedecisions knowing they have to be consistent with the ATWP. Ultimately decisions could be referred to theSecretary of State for Transport to ensure that the decisions fit with the policy; however so long as the CAAsets out to operate within the policy, then reference to the Secretary of State should be most unlikely.

5. How does the management of airspace in the rest of Europe aVect flights into the UK?ii) Is there an opportunity to integrate our plans for changes to airspace management more eVectively withthose of other European countries?

i) Management of airspace into and out of the UK is heavily influenced by foreign military and crossborder ineYciencies. Primarily there is too much regionalism and fragmentation, which has lead to a highlevel of ineYciencies across the European ATC system. The European ATC structure has grown organicallyand historically as states have formed and developed with ATC sectors following national borders, limitingtheir ability to take account of pressure points and key routes for traYc. The system is therefore aVected bya number of historical issues and pressures eg, military control. Where national airspace boundaries exist,analysis has shown routings are 15% less eYcient. As an example, Maastricht area is the only airspace areathat is not based on historical boundaries and the higher performance in this area over other Europeanairspace, demonstrates the significant improvements that are possible.

ii) The issue of integration of European airspace management needs to be tackled strategically. We viewSESII as the ideal vehicle for European integration and in addition we are making moves to speedimprovements by working on the UK and Ireland FAB. We support SES initiatives, but the political willneeds to exist to make the changes happen. Other governments seem to be determined to maintain control,but this doesn’t mean that we shouldn’t try to make changes within the structures available, and supportinitiatives for cross border working.

6. What opportunities are there to apply new techniques and technologies to reduce wasteful flying on indirectroutes and excessive “stacking” while planes wait to land?ii) How can the potential of any such opportunities best be realised?iii) Could environmental benefits be gained as a result of such improvements?

i) There are many opportunities available to reduce waste and ineYciency across the ATC system, rangingfrom altered descent and approach profiles, timed arrivals and optimal level flying. Airlines would alreadyuse these techniques if they were not constrained by UK and European ATC practices, which we believe canbe made more flexible. The SESAR programme has already identified opportunities to enhance safety andimprove eYciency making it vital that SESAR early deliverables are fully supported by NATS and deliveredby 2012.

As part of the drive to improve Heathrow performance, DfT has taken the initiative, asking the CAA tolook at runway resilience to improve the passenger experience and to reduce wasteful emissions. BA has beeninvolved with other stakeholders in developing ideas in this work; however, as the work is ongoing, we leaveit to the CAA/DfT if they wish to comment further at this stage. We believe there are significant changes andeYciencies that could be made in usage of runways which could give wide reaching benefits in many keyareas; reducing stacking, fuel burn, noise and emissions and direct passenger benefits reducing passengerdelays.

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Ev 196 Transport Committee: Evidence

Given the scope of benefits of the runway resilience initiative, we consider it would be beneficial to moveto implement a range of changes soon. Close cooperation between NATS, CAA (DAP) and BAA would beneeded to drive implementation forward. We strongly believe there is no reason for LHR not to have greaterresilience and performance well before the 2012 Olympics and that to set a clear goal for all parties involved,this should be a named target by which the improvements must have been progressively implemented.

European airspace rationalisation is key to unlocking much Pan-European ineYciency—with savings inthe realm of £4 billion across Europe. These savings can only be realised if the whole of EU participates inSESAR. The environmental benefits will follow naturally from this. Ultimately, it is a question of nationalpolitical will to design and implement cross-border, eYcient airspace integration.

In addition aircraft technology is already very advanced with GPS providing ultra accurate tracking andRNAV allowing more flexible inbound routings. There is unrealised potential to use this existing technologyon a trial basis to vary routes for fuel eYciency and noise profile purposes, however restrictive and onerousconsultation requirements often inhibit the pursuit of these potential eYciency enablers. We suggest thatAirports and NSP’s should be able to test certain changes on a strictly trial basis, with defined parametersand timescales but outside of the consultation process, with notification to aVected parties. Permanentchanges as a result of the trials can then go to consultation on basis of hard evidence from all those involvedand aVected, allowing accurate comparison of costs and benefits.

iii) Airlines are naturally driven to reduce fuel burn to cut fuel costs and the cost of emissions—as a roughexample, every ton of fuel saved, is 3 tons of Co2. If Governments and airspace providers focus on removingrestrictions and improving capacity, making airspace more eYcient and eVective, then environmentalbenefits will automatically flow without contrived or complex strategies and limits on traYc. The EU willrequire emissions permits for aviation to be purchased from 2012. If national governments were responsiblefor purchasing the 12% of emissions permits that are needed due to slow progress in allowing eYciency indesign of airspace across national borders, this might spur progress.

7. In relation to the redesign of UK airspace, is the allocation of the roles and responsibilities of each of theinterested parties-Department for Transport, the CAA, airport operators, NATS, etc appropriate and clearlyunderstood?ii) Are the structures of the parties appropriate for undertaking the roles that they should play?

i) This question is fundamentally about lack of clarity, which is causing lack of progress in producing amaster plan and implementing change. We believe it is unclear to all those involved where ultimateresponsibility for driving the redesign forward and making decisions lies.

ii) This is new territory for airspace development; the UK has not built a major new runway in the SouthEast for generations, nor has there been a strategically planned airspace redesign to cope with suchexpansion. Formerly there was not the level and spread of airspace congestion and future demand for growththat we see today.

There are structures and organisations already in place that may be potentially appropriate to meet thenew challenges. However clear leadership is needed, with clear roles and responsibilities of DfT and CAA,to use these existing structures, organisations and expertise.

8. Do airspace management considerations delay the planning processes in relation to airport developmentproposals?ii) How will airspace management considerations be taken into account by the proposed new InfrastructurePlanning Commission, and the relevant National Policy Statements on airport planning?

ii) Previously airspace-planning proposals have been concentrated on step-by-step improvements toexisting runways’ capacity, not new runway build. Now we are confronting the combined situation of tryingto add runways whilst adding to the load on airspace from existing runways. The considerations are complexand if not carefully managed to a timetable that allows for reasonable but not excessive consultation, havethe potential to create delay to progress, as mentioned in our previous answers (see Q1 (iiii)).

ii) BA understands that airspace management is not in the scope of the IPC. BA has come to theconclusion that the issues of strategic airspace design can best be addressed through more clearly directeduse of existing structures and expertise (see answer to Q 7 (ii), and it is not appropriate to refer to the IPCin this specialist area.

BA regards it as a matter for the government as to how airspace management considerations are takeninto account in relevant National Policy Statements on airport planning. In BA’s view the great majority ofwhat should be in a National Policy Statement on airport planning is already contained in the 2003 ATWP,the 2006 Progress report on the ATWP, various other documents (such as the recently published aviationemissions cost assessment), and (in the case of Heathrow), in the consultation on Heathrow runways earlierthis year—on which we await a government decision.

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Transport Committee: Evidence Ev 197

9. What could be the implications for smaller airfields, recreational flying and helicopters of changes toairspace management to enable safe and eYcient increases in capacity at the UK’s major airports?ii) How should an appropriate balance between conflicting priorities be determined?

i) There is a growing national need for air transport services expansion, and for those services to beoperated with less delay, first and foremost at Heathrow, but also at other commercial airports across the UKserving millions of passengers every year. This long term commercial demand growth needs to be addressedstrategically in terms of aVording priority (for airspace development) to the biggest, nationally andregionally important airports, and in terms of a pricing policy for airspace use that reflects the workloadcreated by each flight.

Each movement regardless of size of aircraft is a demand on the system, and impacts available capacity.Light and recreational users may not use the full range of ASP services, but nevertheless can be a demandon the system and impact commercial aviation but without paying a towards this. In addition, short hauloperators pay significantly lower charges due to the user charge calculations working on weight. In eVectcommercial users are subsidising light aircraft and recreational flying, whilst long haul carriers subsidiseshort haul. Changes in charging mechanisms need to be implemented to make the charging fairer and relatedto the actual workload per unit, and to generate suYcient revenue for ASP’s to continue to invest inproviding the increasing capacity. Whilst the charging framework is governed by European regulation, inSES I rules allows modulation to charges in areas of congested airspace, to incentivise eYcient use. Wesuggest that significant areas of airspace within the UK and particularly in the SE/London Sectors wouldbenefit from such modulation.

ii) To allow all users to maintain access to airspace, and to prevent light users impacting capacity whilstmaintaining safety, it is imperative that they should be mandated to carry suYcient levels of equipment. Thiswill facilitate safety improvements by eYciently tracking and enabling distribution of users whilst improvingcapacity eYciency by reducing the separation distances.

We also perceive there may be too much controlled airspace at low levels in London area, and that if theseaircraft had suitable levels of equipage, some lower levels could possibly be raised to provide moreopportunities for non-commercial users.

In converse, we have great concerns that OFCOM Spectrum pricing proposals would have adverse eVectson both safety and capacity if they were to be implemented. Light aircraft and small airfields that currentlyuse radio would potentially be unwilling to pay the Spectrum pricing charge so resulting in large numbersof unknown movements inter weaving with commercial aircraft. This is not only a safety issue, but wouldalso have severe capacity impacts on the airspace as ASPs would be required to introduce greater separationdistances between aircraft.

10. Will it be possible to recruit and train staV in order that airspace changes can be implemented in parallelwith additional airport capacity?

Given lead-time for recruitment, training and testing within the airspace environment, NATs needs to bedirected within the framework of a master plan, to start planning ahead to meet projected capacity increases,rather than waiting until demand is needed. There also needs to be separate resource for operational use anddevelopment and investment as currently it is a shared resource, which is drawn and withdrawn accordingto operational needs, and both requirements suVer.

11. Who should fund airspace changes? Is there likely to be enough funding to undertake the redesign requiredto bring about the necessary additional airspace capacity?

Ultimately users need to fund development. Charges need to be apportioned in the right way, if you canimprove performance, then benefits are self-funding and can be seen as investment. Regulation needs to settargets on a whole range of issues: track miles and fuel burn, delay minutes, flow management, performance,and successfully bringing more capacity on stream and ensure the targets are met. This would enable creationof a performance reward system. As developments are successfully brought on line and performanceimprovements are made, actual financial benefits are realised and funding and benefits will flow.

October 2008

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Memorandum from the Civil Aviation Authority (AIR 33)

Introduction

1. The Civil Aviation Authority (CAA) welcomes the Transport Committee’s inquiry into the use ofairspace as an opportunity to generate discussion around the future airspace requirements for the UK.

2. The CAA was established as a statutory corporation by the Civil Aviation Act 1971, independent ofGovernment, and continued by the Civil Aviation Act 1982. The main statutory functions of the CAA are:safety regulation of civil aviation within the UK; determining policy on how UK airspace is utilised to meetthe needs of all stakeholders; economic regulation of the designated airports and of the provision of en routeair traYc services (through the National Air TraYc Services (NATS) Licence); licensing of airlines in relationto their finances; and licensing of air travel organisers.

3. The CAA also plays a role in providing independent policy advice on aviation issues to Government,which includes: identifying and developing policy on core aviation issues; collaborating externally withnational and international aviation organisations and regulatory bodies; providing a link between industryand the Government; advice on changes to UK airspace arrangements that might have an eVect on theenvironment; advice to Government on proposed European legislation aVecting aviation; and issues relatingto consumer policy and passenger experience.

4. Within the CAA, the Directorate of Airspace Policy (DAP) is responsible for the planning andregulation of all UK airspace, including the navigation and communications infrastructure to support safeand eYcient operations. DAP is staVed by civilian and military experts with experience of commercial,business, recreational and military aviation. The power to make decisions regarding the use of UK airspaceis vested in the Director of Airspace Policy.

5. The report of the independent strategic review of the CAA carried out by Sir Joseph Pilling waspublished in July 2008. As a starting point in his report, Sir Joseph stated, “the CAA is a world-classregulator” and said that his recommendations were “intended to help a good organisation become evenbetter”. He found that under the CAA’s regulation, UK aviation had achieved one of the highest levels ofaviation safety in Europe; that the CAA has managed safety and economic regulation without conflict andthat there are significant advantages to having both functions in the same organisation; and that the CAAhas improved its service delivery performance.

Legal Basis for Airspace Policy

6. The Transport Act 2000 sets out the CAA’s air navigation functions in Part 1, Chapter III. Section 70sets out the CAA’s general duty for this purpose. The overarching requirement to maintain a high standardof safety in the provision of air traYc services set out in Section 70(1) is a duty that has priority over theother objectives summarised below:

a) to secure the most eYcient use of airspace consistent with safety and expedition;

b) to satisfy requirements of users of all aircraft (three categories of airspace users: CommercialAviation, Military and General Aviation);

c) to take account of wider airspace interests;

d) to take account of environment objectives (set out in the Guidance to the Civil Aviation Authorityon Environmental Objectives relating to the exercise of its air navigation functions);

e) to facilitate the integrated operation of ATS by the Crown and others;

f) to take account of national security; and

g) to take account of international obligations.

The CAA must exercise its air navigation functions so as to impose minimum restrictions on ATSproviders consistent with the above.

7. The CAA’s air navigation functions are set out in the CAA (Air Navigation) Directions 2001 asamended by the CAA (Air Navigation) (Variation) Direction 2004 (the Directions) given to the CAA underSection 66(1) of the Transport Act 2000 by the Secretary of State for Transport and the Secretary of Statefor Defence and the Guidance to the Civil Aviation Authority on Environmental Objectives relating to theexercise of its air navigation functions (Environmental Guidance). The Directions established the duty ofthe CAA to develop, promulgate, monitor and enforce a policy for the sustainable use of UK airspace andfor the provision of necessary supporting infrastructure for air navigation. In particular, the CAA is to:

a) provide advice to Government in the context of both national and international arenas;

b) be responsible for the form and content of the UK Aeronautical Information Publication (AIP)and ensuring that an Aeronautical Information Service (AIS) is provided in accordance withinternational obligations;

c) determine and procure the provision of a Lower Airspace Radar Service (LARS) in UK airspace;

d) discharge the responsibilities of the UK Meteorological Authority;

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Transport Committee: Evidence Ev 199

e) prepare and maintain a co-ordinated strategy and plan for the use of UK airspace for airnavigation;

f) develop, apply and maintain a national policy for the classification of UK airspace, includingdesign criteria, rules, guidelines and common procedures;

g) co-ordinate, determine and promulgate temporary changes in the utilization of UK airspace tomeet special air navigation requirements;

h) provide support for the analysis and categorisation of reported risk-bearing occurrences;

i) develop, monitor and enforce a national policy for the use and assignment of civil aeronauticalradio frequencies and Secondary Surveillance Radar codes;

j) establish and promulgate consultation arrangements with the Ministry of Defence (MOD), DfTand air traYc service providers;

k) ensure the continuation of the body known as the Joint Air Navigation Services Council(JANSC); and

l) take account of the environmental guidance.

8. The Environmental Guidance sets out a clear framework within which the Director of Airspace Policywill operate in discharging the CAA’s air navigation functions and centres on:

a) the need to reduce, control and mitigate the environmental impacts of civil aircraft operations, andin particular the annoyance and disturbance caused to the general public arising from aircraft noiseand vibration, and emissions from aircraft engines;

b) the need for environmental impacts to be considered from the earliest possible stages of planningand designing, and revising, airspace procedures and arrangements;

c) where such changes might have a significant eVect on the level or distribution of noise andemissions in the vicinity of a civil aerodrome, to ensure that the manager of the aerodrome, usersof it, any local authority in the neighbourhood of the aerodrome and any other organisationrepresenting the interests of persons in the locality, have been consulted (which might beundertaken through the consultative committee for the aerodrome where one exists);

d) where such changes might have a significantly detrimental eVect on the environment, to advise theSecretary of State for the Environment, Transport and the Regions (now DfT) of the likely impactand of plans to keep that impact to a minimum;

e) the need for the Directorate to provide expert technical advice to the Secretary of State onenvironmental matters; and

f) the need for the Directorate to provide a focal point for receiving and responding to aircraft-relatedenvironmental complaints from the general public.

Civil/Military Arrangements

9. The CAA (Air Navigation) Directions outline safeguards for the civilian and military Joint andIntegrated (J&I) concept of Air TraYc Management mandate for the underpinning agreements to be put inplace and for the continuation of the Joint Air Navigation Services Council (JANSC) to sustain and developJ&I arrangements. The J&I concept relates to a collaborative approach by the CAA, NATS En Route plc(NERL) and the MOD to the separate functions of airspace policy and planning and air traYc serviceprovision. Within this concept it is recognised that airspace is a joint resource and that expeditious accessto all airspace should be available to all users, with the exception of airspace segregated for safety reasons.The underpinning arrangements are sustained through a Memorandum of Understanding (MoU) betweenthe CAA and the MOD, through the NATS En-Route Licence and through an Operating Protocol betweenNERL and the MOD, approved by the CAA. The purpose of the JANSC is to enable the CAA to overseethe arrangements between NERL and the MOD and ensure that air traYc services continue to be providedon a joint and integrated basis. It is the arena for discussing and resolving diVerences of opinion and disputesbetween NERL and the MOD concerning arrangements set out in the Operating Protocol and seeks to keepto a minimum the occasions on which disputes are referred to the CAA.

Airspace Policy

10. The Airspace Change Process, and the Airspace Change Process Guidance document, CAP 725,describe the process and responsibilities established to ensure that proposed changes to UK airspace areinitiated, considered, refined, approved and implemented in a safe and controlled manner. The processallows for consultation on proposals with representatives of airspace users, aerodrome operators andproviders of air traYc services and other bodies and individuals as appropriate who may be materiallyaVected by any changes proposed by the CAA in UK air navigation arrangements. The Process andGuidance are made available on the CAA website as well as in formal publications. A review of the AirspaceChange Process was instigated in 2005 with a view to strengthening the Process in light of the practicalexperience gained over recent years and, in particular, to provide greater clarity on the roles and

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responsibilities of those involved, the consultation activities and the environmental assessment requirementsof any change. The review included extensive consultation with all major interest groups and the revisedmaterial was published in 2007.

11. When reaching a decision on any proposal, it is DAP’s responsibility to ensure that the 7-step AirspaceChange Process has been followed correctly, in accordance with the guidance, and to weigh up competingdemands on the basis of the information provided by the Airspace Change Sponsor, using anysupplementary material requested and in-house knowledge and experience. As part of the airspace changeprocess the Directorate’s Environmental Research and Consultancy Department (ERCD) prepares anobjective report on the proposer’s assessment of the environmental impact of the airspace change. Thisreport comments on the validity of environmental information presented and identifies the limitations ofthe environmental assessment undertaken by the proposer. This enables the Director of Airspace Policy tobalance the environmental impact of the airspace change against the benefits and eYciency gains of theairspace change. The requirements for environmental data to be submitted as part of an airspace changeproposal are described in detail in the environmental sections of CAP 725. The decision on whether to acceptor reject an airspace change is based on careful scrutiny of the merits, or otherwise, of the proposal.

12. ERCD also advises Government on aircraft noise issues—this, in fact, constitutes the major part ofits activities. It also, with the Department for Transport’s encouragement, provides its services to a rangeof organisations on a consultancy basis.

International and European Dimension

13. The UK’s geographic location brings with it a number of international obligations not only in respectof its sovereign airspace but also in respect of high seas airspace for which the UK has accepted responsibilityunder the Chicago Convention for the provision of air traYc services. Additionally, there are a considerablenumber of European influences, which need to be taken into account when considering UK airspace anddeveloping policy for the future, including the impact of European legislation on UK airspace managementand operation. Indeed, European initiatives aVecting regulation and other aspects of aviation are now amajor focus for the CAA. The CAA has a number of functions that have been defined by UK Government.For example, the CAA acts as a “Competent Authority” undertaking safety regulatory activities as part ofthe EASA system. The CAA also engages actively on policy formation, both on behalf of DfT andindependently, with the European Commission and other European aviation bodies. In addition, the UKCAA has been appointed as the National Supervisory Authority in Single European Sky terms by the DfT.

ICAO

14. The UK is a member of the International Civil Aviation Organisation (ICAO), a United Nations(UN) body with 189 member countries. ICAO has been in place since the birth of international civil aviationat the end of the Second World War, and its role is set out in the 1944 Chicago Convention, the internationaltreaty that governs civil aviation. As a member, the UK agrees to adopt the standards and recommendedpractices concerning air navigation, prevention of unlawful interference, and facilitation of border-crossingprocedures for international civil aviation published in ICAO Annexes. Contracting States to the ChicagoConvention recognise that every State has complete and exclusive sovereignty over the airspace above itsterritory. ICAO provisions that directly impact on airspace arrangements are contained within Annex 2(Rules of the Air) and Annex 11 (Air TraYc Services) to the Convention on International Civil Aviation.

European Context

15. In certain areas across the European network, air traYc management (ATM) capacity limits werereached in the late 1990s. Operational delays to flights became common and the European Commissiondecided to take action to address this. The Single European Sky (SES) initiative was conceived to create amore rational organisation of European Airspace and create capacity, whilst maintaining high safetystandards. To achieve this, SES aimed to create an ATM system that was designed, managed and regulatedin a harmonised way. The first package of SES legislation came into force in April 2004; it has delivered somebenefits including a harmonised regulatory framework across Europe for ATM, which provides theinstitutional arrangements required to enable States and Air Navigation Service Providers to deliveradditional capacity. However, many of the SES concepts are still relatively immature, and an ongoingprogramme of development of Implementing Rules (IRs) to flesh them out is still underway and,consequently, we have yet to see major capacity benefits as a direct result of SES. Nonetheless, these IRsincreasingly impact on many aspects of European ATM, including the design and operation of airspace, AirTraYc Services charging arrangements and the regulation of ATM. During 2008, the European Commissionhas launched a new initiative known as the SES II package to accelerate the implementation of the firstpackage of measures, to introduce further performance-enhancing measures and to ensure ATM plays itspart in achieving sustainable aviation. These issues are further explained at paragraph 33.

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EUROCONTROL

16. EUROCONTROL is the European Organisation for the Safety of Air Navigation, created in 1963by six founding members. This civil and military inter-governmental organisation is now formed of 38Member States from across Europe. EUROCONTROL’s objective is the development of a uniform pan-European ATM system, embodied in the concept of a Single Sky for Europe, which will contribute tomaking European aviation safer, more secure and more environmentally friendly. The governance structureof the Organisation is composed of three bodies: two governing bodies, the EUROCONTROL Commissionand the Provisional Council, and one executive body, the Agency. In particular, the Agency performs thefollowing functions from a pan-European perspective:

a) The Central Flow Management Unit (CFMU) provides Air TraYc Flow and CapacityManagement (ATFCM) to airspace users throughout the European States to avoid overloads andto ensure that available capacity is fully exploited.

b) The Central Route Charges OYce (CRCO) of EUROCONTROL bills and collects en-routecharges on behalf of Member States by virtue of a common policy that builds on the provisionsof the Multilateral Agreement relating to Route Charges. Route charges remunerate the costsincurred by the EUROCONTROL Member States for providing en-route services to the users oftheir airspace.

c) EUROCONTROL’s Maastricht Upper Area Control Centre (UAC) ensures the safe, eYcient andexpeditious flow of civil aircraft in the upper airspace (above 24,500 feet) of Belgium, theNetherlands, Luxembourg and the North-West of Germany. A Deutsche Flugsicherung (DFS)unit, controlling military air traYc over the North-West of Germany, is co-located with the civilfacilities.

d) The Agency develops implementing rules which complement the high level Regulations adoptedby the European Parliament and Council.

17. The Airspace, Network Planning & Navigation Division (APN) focuses on the design and planningfor a cost-eYcient, dynamic pan-European ATM network operation; their activities bring together all thekey elements of: Capacity Enhancement Planning ATS Route Network and ATC Sector Design; AirspaceManagement; and Improved Civil-Military Coordination.

Current Issues

Air Transport White Paper

18. In December 2003, the Government set out a long-term strategy for the sustainable development ofair travel for the period up to 2030. This strategy aimed to balance the growing aspirations of the public totravel and the needs of the UK economy together with the requirement to protect the environment. Itproposed a comprehensive strategy that:

a) committed the Government to ensuring that aviation reflects the full costs of its climate changeemissions, which will influence the amount of traYc growth that will occur;

b) put in place tough local environmental conditions for the UK’s most environmentally sensitiveairport, London Heathrow. Further expansion in flights would not be allowed unless limits onnoise and air quality could be met;

c) recognised that aviation brings real benefits to the lives of ordinary people and to business. Itconnects people and places in ways that many people value highly and is also critical for asuccessful economy;

d) did not take forward proposals for new capacity at several airports and at new green field locations,and instead promoted making better use of existing airport capacity. The strategy supported thedevelopment of regional airports mostly within existing capacity, as well as the construction of afurther runway at Stansted and at Heathrow, and measures to make better use of existing runwaysat those airports.

The White Paper set the context for the environment within which the CAA performs its airspacefunctions.

Air Transport White Paper Progress Report

19. In December 2006, the Government published a Progress Report on the White Paper, which providedupdates in the following key areas:

a) Prioritisation of optimisation of the UK’s existing airports through a process of improvement andmodernisation. Growth and developments at regional airports, without the need for new runways,would provide improved access across the country to air travel from modern airports. Edinburghand Birmingham airports, where new runways were supported, do not now expect to build themuntil some time after 2020.

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b) At Heathrow, where The Future of Air Transport White Paper indicated that a new runway couldbe delivered in the period 2015 to 2020, expanding the airport is conditional on meeting the noiseand air quality limits that the DfT set. Consultation would take place to determine whether theenvironmental impact of making more use of existing runways, or building a third runway, wouldbe acceptable.

c) At Stansted, potential for the second runway would need to follow the due planning process.

d) An update of the Government’s forecasts of air passenger demand and changes in the aviationindustry was provided.

e) The report set out the progress achieved towards meeting the strong demand for air travel, butaYrmed that this needed to be delivered in a way that balanced the need to manage aviation’senvironmental obligations.

f) The report also set out specific next steps in delivering the Government’s policy.

It is against this backdrop, where decisions are still awaited from the consultation and planning process,that the CAA continues to evaluate airspace change proposals.

Providing Advice to Government

20. In the context of this Inquiry and the Directions, the Directorate of Airspace Policy has a remit toprovide advice and assistance to the Secretary of State for Transport and the Secretary of State for Defence.In the main, this advice is oVered as technical assistance to the DfT and takes a variety of forms eg it includesdirect participation in DfT-run project or programme Boards, such as in the case of Project SustainableDevelopment Heathrow (PSDH), involvement in international negotiations on matters such as the SingleEuropean Sky or responding to formal consultations. In addition, DAP staV have routinely providedtechnical advice and assistance to Defra, BERR, Ofcom, other non-Government departments and to theInspector at Planning Inquiries, such as at the Coventry inquiry in 2006 where the Inspector’s report statedthat CAA input was highly valued.

Strategic Review of the CAA—Environmental Recommendations

21. In his Report on the Strategic Review of the CAA, Sir Joseph Piling recommended that the CAA begiven a general statutory duty in relation to the environment, which would be set within a policy frameworkthat would provide a clear boundary between the roles of the Department, other stakeholders and that ofthe CAA. The Review recognised the diYculty of producing an environmental policy framework in thecontext of aviation but stated that there needed to be suYcient context and detail to enable the CAA to reachdecisions that were aligned with Government policy. He also recommended that the guidance on theenvironmental objectives in relation to the CAA’s Air Navigation functions be reviewed. The CAAwelcomes the report overall and we are considering the detail of the recommendations; we look forward toworking with the DfT in progressing the issues.

Future Airspace Strategy (FAS)

22. Planning for future airspace requirements results from a complex mix of international agreements anddomestic aviation and transport policy. Furthermore, separate ownership of the airports situated within thebusiest and most complex airspace in the southeast of the UK could further complicate currentarrangements and generate potential conflicts that will need to be addressed in the future. The internationalcontext is driven from obligations stemming from the Chicago Convention, which are imposed upon theUK as Standards and Recommended Practices, through European legislation emanating from both theEuropean Single European Sky proposals and, increasingly, from the European Aviation Safety Agency(EASA). It is the task of the Directorate of Airspace Policy, working very closely with colleagues in otherparts of the CAA, NATS, the MOD and wider industry to turn this complex combination of inputs intosustainable policy for the safe and eYcient use of UK airspace. In this context, the CAA has recentlycommissioned NATS, as the monopoly en-route service provider, to initiate a study into the futurerequirements for airspace, air traYc management and navigation policy for the busiest portions of UKairspace. This work has been called the Future Airspace Strategy and NATS is engaged currently in the earlystages of scoping the project. The Strategy will look out to the end of the Air Transport White Paper planningtimeframe of 2030 and, in the context of emerging drivers for change emanating from Europe, in the formof the SES II proposals and the SESAR project (described in paragraph 32). The Strategy will seek todetermine the optimum evolution of UK airspace that will deliver high levels of safety in a sustainablemanner, while meeting the anticipated demand in the most eYcient way possible and making the best useof the available technology. The Strategy will also ensure that where changes are required to existingairspace, these new arrangements provide a structured and cohesive approach over a long period that willmeet the necessary capacity demand. The initial stages of this work have highlighted a number of key issuesthat can be grouped into four requirement areas under the headings of: airspace policies, regulatory process,technology mandates and equipage, and environmental policies. These issues are now being progressed inconjunction with DfT, NATS and the MOD.

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Competition Commission Investigation into BAA Airports

23. The CAA submitted a number of papers, submissions and oral evidence throughout the CompetitionCommission’s Investigation into BAA Airports. All of the material is available on the CompetitionCommission’s website at:

http://www.competition-commission.org.uk/inquiries/ref2007/airports/index.htm

Environmental issues

24. The profile of environmental issues in relation to aviation has risen in recent years. Within this widerdebate, there has been significant focus on aviation’s impact, both locally (eg noise and air quality) andglobally (eg climate change). Further policy developments from the Government (eg continuing delivery ofthe Future of Air Transport White Paper agenda and recently published White Papers on energy andplanning), the publication of high-profile reports with an international dimension (eg the Stern Review andrecent reports from the Intergovernmental Panel on Climate Change), published against a background ofalready high public interest, combined with the steady growth in air traYc and the need to provide extracapacity at UK airports, will ensure that aviation retains a high profile in environmental terms. The currentoperating environment and economic pressures have resulted in flight eYciency featuring highly on theagenda of airspace users and Air Navigation Service Providers and, in addition, this has positive benefitsfor the environment.

25. While the CAA exercises its main functions in safety, airspace policy, economic and consumerregulation, it also has a number of environmental roles in the context of its statutory functions. The CAA’sspecific environmental responsibilities set by the UK Government include: assessing environmental issueswhen deciding any changes to UK airspace; undertaking noise studies for Government, airports and localauthorities; advice on the economic impact of environmental policies, and specialist advice to Government,including studies on Aviation White Paper proposals.

26. Within an airspace design context there are a number of competing environmental factors that needto be considered and that will aVect the final decision. The CAA (Air Navigation) Directions require theCAA to take account of “the need to reduce, control and mitigate as far as possible the environmentalimpacts of civil aircraft operations, and in particular the annoyance and disturbance caused to the generalpublic arising from aircraft noise and vibration, and emissions from aircraft engines”. In order to achievethis, DAP requires Airspace Change sponsors to provide an environmental assessment of their proposalwhich should include: traYc forecasts; an assessment of the eVects of noise; an assessment of the change infuel burn/ CO2; an assessment on the eVect of local air quality, and an economic valuation of theenvironmental impact, if appropriate.

27. There are also a number of environmental factors that can be improved or worsened (or remainunchanged) when airspace changes are implemented. These include noise impact on the population, aviationemissions such as CO2, local air quality, the impact upon tranquillity and visual intrusion. In many cases,these factors may act as opposing influences when designing airspace and routes. Two examples of suchconflicts are:

a) Aircraft noise versus fuel burn and green house gas emissions. In order to minimise the amount offuel burnt (and thereby minimise emissions), direct routings are preferred because they reduce thetrack mileage that each aircraft flies. However, a more direct route may take an aircraft directlyover a centre of population thereby aVecting a greater number of people in terms of the noiseimpact.

b) Minimising the population overflown versus tranquillity and visual intrusion. In order to minimisethe number of people overflown (and thereby reduce the number aVected by aircraft noise) flightssometimes can be routed away from centres of population. However, this could mean that they flyover areas that are less densely populated such as Areas of Outstanding Natural Beauty and/orNational Parks. This could have an impact upon the special qualities of such areas by reducingtranquillity and/or causing visual intrusion. Whilst there are physical limits that will set the limitfor the visibility of any object, the issue of visual intrusion is subjective, and individuals will havediVering opinions and perceptions.

There is no pre-determined formula for assessing these diVering impacts and consequently the CAA isrequired to exercise its judgement, based on the requirements set out in the Transport Act 2000.

28. It is feasibly an over-simplification to suggest that airlines will always seek to reduce fuel burn as theoverriding operational consideration. It is perhaps fairer to say that airlines will always seek to minimisecosts, and as the cost of fuel increases, then the amount of fuel used becomes a more significant factor. Whilstthe price of fuel is only one element of the cost base for airlines, it is playing a more predominant role andgaining in significance as an influencing factor for operators in deciding the most “eYcient” route and inseeking to use airspace eYciently; as a consequence, this is generating environmental benefits.

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29. One of the techniques that can be employed to minimise the noise eVect is Continuous DescentApproaches (CDAs), an operational procedure that has been developed which results in both a fuel savingand a reduction in the noise impact when aircraft are approaching an airport to land. All airspace changesponsors are asked to consider how CDAs might be implemented as a result of the proposed change but,for a variety of reasons, eg conflicts with other traYc, sometimes it is not possible to implement CDAs.

30. The delivery of the Government’s aspirations in respect of renewable energy has led to a significantgrowth in wind turbine developments, both on-shore and oV-shore. Inevitably, the construction of thesestructures has led to potential conflicts with aviation as a result of their possible impact on the performanceof technical systems, including radar, and the need for physical aerodrome safeguarding. The CAA has beenworking with Government departments, aviation stakeholders and the wind turbine industry for some yearsto help identify the particular issues and to work to develop appropriate mitigations, which would enableaviation and the renewable energy sector to co-exist, as far as is practicable, whilst maintaining safetyimperatives. To this end, and recognising the requirement for DAP to consider the needs of all airspace users,the CAA has: assisted in developing a pre-planning consultation process; continues to fully participate inthe appropriate Government-sponsored working groups and committees to progress issues; has publishedguidance to assist aviation stakeholders in how they should deal with the planning issues and the impact ofdevelopments; in addition to providing impartial advice and guidance to all stakeholders, includingplanning authorities. More recently, the CAA has demonstrated its commitment to progress the delivery ofwork streams within an Aviation Plan to implement measures designed to mitigate the impact of windturbines on aviation. This was achieved through an MOU signed jointly with BERR, MOD, DfT, NERLand BWEA in June 2008. The potential conflict between aviation and wind turbine development remains along-term issue but is one which Government departments and the CAA see as appropriate for engagementto best serve the disparate needs of the UK.

European Issues

31. It is key that the CAA continues to engage with DfT, European institutions and other NationalSupervisory Authorities in an eVective and constructive manner. The principle of harmonisation and theapplication of common rules across European airspace and air traYc management are fully understood andaccepted. However, it is essential that the UK’s requirements are met and it is therefore important that theCAA’s position and that of the UK aviation sector continue to be reflected in major Europeandevelopments. The CAA will continue to work together with other aviation stakeholders to influence thedevelopment of European regulations and policies and institutional structures to ensure that, whereverpossible, developments are compatible with UK policy and that they are consistent with Better Regulationprinciples.

SESAR

32. SES in itself will not result in a new European ATM system and, in parallel, industry has comeforward with a proposal for a project to define, develop and deploy a new system—the SES European ATMResearch (SESAR) programme. SESAR has now completed its definition phase and the outcome, the ATMMaster Plan, will give rise to considerable research and development work over the next few years. Thisshould lead to the progressive deployment, from seven years hence, of a new European ATM system thatshould sustain European aviation from an ATM viewpoint for the following 30–40 years, whilst also meetingEU-level objectives for safety, environmental impact and eYciency.

SES II, Extension of the EASA System and Airport Capacity

33. Overall, the drivers for a Single Sky have changed with a focus now on areas such as cost,fragmentation of service provision and the environment, rather than just delays. Recognising the challengesthat lay ahead, the Commission set up a High Level Group, comprised of senior figures in European ATM,to make recommendations to improve the eVectiveness of the regulatory framework in Europe. Its report,which was published in summer 2007, set out ten recommendations on what needed to be improved inEuropean ATM, calling for a focus on driving higher levels of performance. Addressing the Report’srecommendations, at least in part, the Commission came forward in June 2008 with a package of proposalsknown as SES II. These proposals aim to amend the existing SES legislation to deal with performance andenvironmental challenges, create a regulatory environment to allow future technology to be developed andimplemented (SESAR), to create a single safety framework for European ATM through the extension of theEASA system and to deliver an “action plan for airport capacity, eYciency and safety”. The CAA continuesto work in partnership with EASA as the Agency’s remit is extended. The CAA recognises that although aconsiderable amount of aviation safety rulemaking will transfer to EASA, there will still be a substantialand vital role for the UK in overseeing the safety performance of its aviation industry, currently one of thelargest in Europe. The CAA, working with DfT, will be closely involved in the discussion of these proposalsas they proceed through the Council and Parliament.

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Answers to Specific Questions set out in the Inquiry

What changes to the management of airspace could be required as a result of the additional airport capacityoutlined in the 2003 White Paper? Are the White Paper’s projections for increased passenger demand stillaccurate? Are all the measures to provide for increased passenger demand likely to be implemented?

34. Whilst it is likely that long-term growth in air travel (as outlined in the Air Transport White Paper)will still occur, the current economic climate may mean that such growth will be achieved later thanoriginally predicted. In the short term, low GDP and consumer expenditure growth, combined with higheroil prices, may lead to air travel becoming more expensive at a time when passengers’ disposable incomes areunder pressure. However, the immediate eVect on passenger numbers will depend to some extent on airlines’responses to these circumstances, whilst in the longer term, economic conditions can be expected to improve.

35. The Directorate of Airspace Policy works to traYc forecasts provided by the DfT and which wereused in drawing up the White Paper and the subsequent Progress Report in 2006. DfT forecasts are subjectto periodic revision to take into account latest developments in the economy and the industry.

36. The Air Transport White Paper encouraged airports to produce and publish Master Plans but thesewere largely based on the individual airports’ aspirations and, in most cases, did not take into account theairspace requirements, nor were they detailed assessments of future market developments. It is, therefore,not surprising that the total traYc forecast obtained by combining the forecasts of individual master plansgreatly exceeds the DfT’s national traYc forecast. The CAA and NATS are of the view that, were all of thesoutheast airport development plans to come to fruition, there would not be suYcient airspace capacity toaccommodate the scale of predicted traYc growth on the basis of current and anticipated technologydevelopments. However, it is unlikely that every airport will implement its original development plan, sincea number of airports (for example Birmingham and Luton) have already indicated that they will not pursuesuch ambitious expansion.

37. There are, potentially, other factors that will also require airspace capacity such as the growth inbusiness jets (including Very Light Jets (VLJ)) and Unmanned Aircraft Systems (UAS) that have not beenaccounted for in existing plans.

Can safety be maintained as airspace is increasingly utilised? Is there a suitable interface between military andcivilian arrangements for air traYc control?

38. The CAA works collaboratively with industry to continuously improve aviation safety and addresssafety issues. The CAA will take any actions necessary to ensure that safety is not compromised and willensure that the high safety standards within UK airspace, and its supporting infrastructure, are maintained,with potential risks identified and appropriate mitigating actions taken.

39. In all of the CAA’s considerations, safety has primacy—in theory and in practice. DAP works veryclosely with Safety Regulation Group colleagues and the service providers to ensure that safety isparamount. There are adequate checks and balances in place to ensure arrangements are safe and, shouldevidence ever indicate that safety could not be maintained, action would be taken to limit the service untilsafety levels are assured. The CAA is working with European and international colleagues, and aviationstakeholders to assess the impact that the introduction of new aircraft and systems, such as VLJs and UAS,will have on airspace arrangements. The risks associated with the introduction of these new operations willneed to be fully understood and mitigated to a level that is acceptable.

40. The International Civil Aviation Organisation (ICAO) has harmonised the approach to SafetyManagement Systems (SMS) for air traYc and aerodromes with the result that SMS has for some time beena reality for Air Navigation Service Providers and airport operators. Work is now underway to extend thisrequirement to Air Operator Certificate holders and approved aircraft maintenance organisations. One ofthe fundamental parts of the ICAO Safety Management System requirements is that each Member Stateshould determine a State Safety Programme. The UK CAA has made progress towards compliance withthis requirement by the publication of documents such as the Safety Plan in 2006 and subsequent updatesand through the revision of other related guidance material. Further compliance will be demonstratedthrough the publication of a CAP detailing the State Safety Programme for the United Kingdom, which hasbeen developed by the CAA in conjunction with the MOD, DfT and Air Safety Support International, andis expected to be published this autumn.

41. The CAA takes a proactive stance to safety worldwide and uses UK data to identify safety trendsapplicable to UK aviation, prioritising this information, using a risk based approach, to focus on the mostsignificant safety issues. The resulting safety improvement initiatives are captured in the CAA Safety Plan,which provides a means of monitoring progress and eVectiveness.

42. The UK’s civil/military interface arrangements are considered by many in Europe to be a model ofbest practice. There is eVective integration on policy matters, service provision and procedure developmentbetween both civil and military service providers and regulators. Indeed, the CAA works closely with themilitary and civil air traYc service providers across all areas to ensure the proper level of coordination ismaintained, from the JANSC through to individual working groups. Furthermore, the interface between

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civil and military air traYc is greatly enhanced and strengthened by the co-location of military units atNATS’ London and Scottish and Oceanic Area Control Centres, where civil and military controllers use thesame data and facilities.

Is the current approach to planning and regulating the use of UK airspace adequate? Would an Airspace MasterPlan covering the period of the White Paper be beneficial? Could a piecemeal approach to individualdevelopments necessitate additional redesigns subsequently?

43. In the initial part of the time span covered by the Air Transport White Paper, existing airspace changeprocesses have delivered the requisite capacity to meet demand. However, forecast growth and particularlyairport master plans have raised expectations and concerns within the industry and amongst the public thatsuYcient airspace capacity will not be available, in particular in the southeast of the UK. In response to this,and the expectations set out in the White Paper, work has started on a Future Airspace Strategy (FAS). Theobjective of the FAS is to set out a strategic plan for the reorganisation of the busiest portions of UK airspaceout to 2025 so as to ensure safety, secure airspace eYciency and deliver the greatest degree of environmentalmitigation, whilst ensuring cohesiveness with European strategies. FAS is designed to avoid the limitationsof a piecemeal approach but it is important to recognise that such a strategy cannot be developed in isolation.ICAO, SES and EUROCONTROL all have increasing influence and importance.

How are the eVects [of] aircraft noise and emissions taken into account when changes are made to the use ofairspace? Who should be consulted about such changes? How should the balance between conflicting interestsbe struck?

44. The Airspace Change Process, as set out in the DAP Airspace Charter (CAP 724) and its associatedguidance in CAP 725, clearly sets out the process to be followed, including the environmental andconsultation requirements. CAP 725 details the individual steps to be followed throughout the process andprovides extensive advice on the environmental requirements, which reflects the high-level Guidance to theCivil Aviation Authority on Environmental Objectives relating to the exercise of its air navigation function(Environmental Guidance). Clearly, there is always a balance to be struck, and in reaching a decision DAPwill consider the individual nature of the proposal in the context of the overarching principles ofenvironmental benefit, airspace management considerations and the overriding need for safety.

How does the management of airspace in the rest of Europe aVect flights into the UK? Is there an opportunityto integrate our plans for changes to airspace management more eVectively with those of other Europeancountries?

45. The UK situation is pivotal to the North Atlantic air traYc flows, between North America andEurope, as well as the north-south flows to and from the Iberian Peninsula and Balearics. Any delays atHeathrow or in UK airspace have a rapid and significant knock-on eVect to the rest of Europe. The existingroute network and design is achieved co-operatively through a process managed centrally throughEUROCONTROL, with the appropriate UK representation. The SES II proposal to establish a NetworkManagement Function is designed to enhance the existing arrangements and to ensure the overall networkeVect is given greater consideration. This is important for the UK due to its geographic location and, as such,we are maintaining close involvement in the development of the SES II proposals. The introduction of theUK/Irish Functional Airspace Block (FAB) has rationalised existing airspace arrangements between the twocountries. Future FAB developments include the proposed Central Europe FAB (FABEC), involvingBelgium, France, Germany, Luxembourg, Netherlands and Switzerland, and their Air Navigation ServiceProviders, including Eurocontrol as the service provider for the Maastricht Upper Area Control Centre. Thearea covered by FABEC is one of the highest traYc density areas in the world made up of over 1.7 millionkm of airspace comprised of closely interlaced civil and military traYc routes and areas. Clearly, there areimportant implications for the UK’s airspace if such a large area of European airspace and its traYc flowswere to be reorganised and, as a direct consequence, the UK has been involved in a number of workinggroups and continues to be an active cooperative partner in the ongoing developments.

What opportunities are there to apply new techniques and technologies to reduce wasteful flying on indirectroutes and excessive “stacking” while planes wait to land? How can the potential of any such opportunities bestbe realised? Could environmental benefits be gained as a result of such improvements?

46. The UK is at the forefront of the introduction of new techniques, with airspace changes underdevelopment that would require Continuous Descent Approaches (CDA) and Precision Area Navigation(PRNAV) routings and profiles. However, it is clear that new tools are required to deliver the gate-to-gateconcept and improved arrival/departure flows. It is hoped that work currently underway in SESAR willdeliver some of the technical improvements that will enable optimisation of direct routings and otherpotential benefits; however, there is insuYcient detail at this time to determine exactly what improvementswill be generated. The Future Airspace Strategy is also designed to address some of these issues and this willneed to be closely aligned with SESAR.

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Transport Committee: Evidence Ev 207

In relation to the redesign of UK airspace, is the allocation of the roles and responsibilities of each of theinterested parties—Department for Transport, the CAA, airport operators, NATS, etc—appropriate andclearly understood? Are the structures of the parties appropriate for undertaking the roles that they should play?

47. The CAA considers that the roles and responsibilities of the principal parties are appropriate, and areclearly understood by those parties. CAP 724 and CAP 725 clearly delineate the roles and responsibilitiesfor DAP and the airspace change sponsor and reflect the essential clear distinction between the changesponsor and the decision maker. The responsibility for undertaking proper consultation should rest,appropriately, with the change sponsor who after all must own the implementation of the final airspacearrangements and will be responsible for safe service delivery. The Directions provide that, where changesto the design or to the provision of airspace arrangements or to the use made of them which might have asignificant eVect on the level or distribution of noise and emissions in the vicinity of a civil aerodrome orunder the arrival tracks and departure routes followed by aircraft using a civil aerodrome but not in itsimmediate vicinity, the CAA shall refrain from promulgating the change without first securing the approvalof the Secretary of State. However, although these roles and responsibilities are clear to those principallyinvolved, the wider public does not fully appreciate the individual roles of the CAA, DfT, airport operatorsand Air TraYc Service Providers and their associated responsibilities with regard to airspace.

48. DAP is properly resourced with the right mix of technical expertise to deliver airspace change inrelation to the duties as currently defined in legislation and statutory duties. Clearly, this will need to be keptunder review if any changes to the CAA Directions or associated Guidance occur as a result of the StrategicReview Report. It may then be necessary for CAA to recruit individuals with diVerent areas of expertise,such as in the area of emissions, to provide the necessary structure.

Do airspace management considerations delay the planning processes in relation to airport developmentproposals? How will airspace management considerations be taken into account by the proposed newInfrastructure Planning Commission and the relevant National Policy Statements on airport planning?

49. Evidence shows that all Airspace Change proposals have been delivered against their original targetdates, where it has been appropriate to approve the change. Where there is a need to build new infrastructure,airport operators have accepted that airspace change elements can be delivered within their requiredtimescale and this is not a limiting factor in their planning considerations. Airspace managementconsiderations will only feature in the Infrastructure Planning Commission (IPC) where the development islarge enough to reach the IPC threshold even then, the precise nature of any airspace related decision is yetto be determined. In all other cases the Airspace Change Process will be followed.

What could be the implications for smaller airfields, recreational flying and helicopters of changes to airspacemanagement to enable safe and eYcient increases in capacity at the UK’s major airports? How should anappropriate balance between conflicting priorities be determined?

50. The UK has a finite amount of airspace, although capacity to move air traYc can be increasedthrough re-sectorisation and through advances in technology. Particularly in the southeast of the UK,airspace is in great demand for use by Commercial Air Transport and the General Aviation community.Current airspace arrangements have, to date, enabled the competing requirements to be met, albeit often byreaching a compromise solution that while safe, does not fully meet the needs of all user groups. Historically,where priorities conflict, priority has been given to meeting the demands of major airports and the needs ofrecreational flying have been accommodated where they can, without impacting on the safe operation ofCommercial Air Transport. There is a requirement to take into consideration the needs of all airspace usersand the interest of the public as a whole when determining policy for the safe and eYcient use of UK airspace.Helicopter operations can be accommodated safely through normal Air TraYc Control arrangements.Within the London Control Zone the arrangements for helicopter activity have been reviewed recently andenhancements put in place.

Will it be possible to recruit and train staV in order that airspace changes can be implemented in parallel withadditional airport capacity?

51. CAA resources are not a limiting factor in the approval of airspace change proposals at the currentrate of delivery. It is not anticipated that this will change significantly in the years ahead as the Air TraYcControl system can only cope with a finite amount of change each year. Such changes are only generallymade in the spring and autumn to avoid the peaks of traYc conventionally experienced during the summermonths and this enables the workload to be managed eVectively.

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Who should fund airspace changes? Is there likely to be enough funding to undertake the redesign required tobring about the necessary additional airspace capacity?

52. Notwithstanding the need to consider the environmental benefit, airspace changes are normallyinitiated when safety, demand or capacity require it. Whilst anybody can initiate an airspace change, in mostcases the requirement for such a change originates from Commercial Air Transport needs and the CAAprincipally believes that changes will be initiated by an aerodrome operator, an Air Navigation ServiceProvider, or a combination of the two, to meet this commercial demand. Consequently, it is entirelyappropriate that the airspace user community should fund changes as they are initiated to meet theirrequirements.

October 2008

Memorandum from Mrs Alastair Robinson (AIR 34)

Stacking of Aeroplanes Approaching Stansted Airport

Richard Spring has informed me that the House of Commons Transport Committee has announced thatit will be conducting an inquiry into the use of air space.

As you will know there is very passionate objection in this area to the alteration in the plans for stackingthe planes waiting to land at Stansted. The new plan would mean the planes would stack in a loop above alarge area of tranquil villages and stud land, at the moment remarkable for its tranquility and undisturbedbeauty. The scenario we are confronted with is that, under the proposed scheme we might have as many as33 planes an hour overhead at a height of a mere 4,500 feet at peak hours, which as you will appreciate willtransform what until now has been a wonderfully peaceful collection of villages and small towns into thegeneral hubbub from which we have chosen to distance ourselves.

People who choose to live in rural areas, and there are many thousands of us, willingly forego theconvenience of immediately local schools, shops, doctors, post oYces etc., for the compensating virtues ofpeace and quiet and the solidarity of a vibrant local community. Must this be threatened so drastically bythe advent of deafening noise which would here be life-changing, whereas flights above many busy townsare scarcely noticed?

I am informed that other European countries seem to manage a far steeper descent for planes waiting toland which causes less disturbance to the surrounding regions and we would really appreciate it if yourcommittee would press the Air Transport authorities to consider this in depth or look more thoroughly atthe stacking of the planes over the Thames Estuary which could be the long term solution. We have of coursewritten to all the relevant authorities about this and hopefully they will at least be considering our objections.Nevertheless we are particularly pleased and relieved to know that you will be conducting an Inquiry intouse of air space. This is a matter of great significance to this small country and particularly to its much lovedrural areas.

September 2008

Supplementary memorandum from the Civil Aviation Authority (AIR 33A)

1. Following the CAA’s appearance before the Committee on 21 January, the CAA is pleased to providethe following additional information, requested by the Committee, which we hope will be helpful to theinquiry.

Airspace and Aerodrome Considerations for Bird Control

2. From the CAA perspective, there is no direct link between airspace capacity and the bird strike riskand, therefore, it is not specifically addressed through the Airspace Change Process. However, any riskassociated with potential bird strikes and the operation of a particular airport or runway will be dealt withthrough the Safety Management System (SMS) of the airport operator. Furthermore, this SMS will be thesubject of oversight by the CAA’s Safety Regulation Group.

3. CAA activity in relation to bird strike risk is conducted at two levels.

a) At the strategic level, in line with international requirements, the Department for Transport hastasked the CAA with the role of hosting the UK Bird Strike Committee (UKBSC). This committeemeets annually, with both national governmental department oYcials and industry stakeholders,to share information and best practice on the subject of bird hazard management. During 2007–08,and as a result of stakeholder engagement via UKBSC members, the CAA conducted a review ofits publication CAP 680 Aerodrome Bird Control and republished it completely as CAP 772 BirdStrike Risk Management for Aerodromes. As well as providing comprehensive advice to aerodrome

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Transport Committee: Evidence Ev 209

licence holders on the subject of the management of the risk of bird strikes, this documentintroduced a set of definitions outlining the scope of confirmed, unconfirmed and near-miss birdstrike events to enable the CAA to conduct smarter analysis of data.

b) At the operational level, responsibilities fall in a number of areas. For example, it is mandatoryfor aircraft commanders to report to the CAA all bird strikes that occur whilst the aircraft is inflight within UK airspace. In addition, the CAA encourages the voluntary reporting ofunconfirmed, or “near-miss” bird strike occurrences. In January 2008, the CAA introduced anonline bird strike reporting system to facilitate easier reporting and data handling. The CAA usesthe UK bird strike data to inform its safety regulatory oversight of aerodromes (eg aerodromeaudits) and to identify any adverse trends. In addition, the bird strike statistics are published onthe CAA website.

4. Additionally, CAA-licensed aerodrome operators are required, as part of their Safety ManagementSystem, to identify the risk to aircraft operations posed by wildlife at their location and to adopt measuresto reduce the likelihood of collisions between wildlife and aircraft. The Airport Operators Association andthe General Aviation Awareness Council, supported by the CAA, have also produced a series of AdviceNotes, which provide advice on proposed developments located within the safeguarded area of anaerodrome, including those likely to attract birds. Operational Air TraYc Control procedures are also inplace to warn pilots of the bird strike risk when it is necessary.

5. In recognition of the specific safety threat posed by the increasing population of Canada Geese, theCAA published, in 2001, a document entitled Large Flocking Birds—An International Conflict BetweenConservation and Air Safety to provide information relating to the management of this particular wildlifehazard. Between 2003 and 2008, there have been 29 reported bird strike events involving geese in the UK.Of these, six resulted in damage to the aircraft and in one case the aircraft returned to the departure airport.However, the overall trend for bird strikes involving geese has reduced from ten in 2004 to four in 2008.

UK Pilot Training for Emergency Landings on Water

6. Current European training requirements for flight crews of commercial air transport aeroplanesinclude the need for pilots to be trained on all major emergencies within a three-year period. IndividualEuropean operators may tailor their training programmes to suit their operation, but the programmes mustbe acceptable to their respective National Aviation Authorities (the CAA in the UK). The programmes needto include all elements required by regulation, must meet periodicity requirements and must addressappropriately perceived safety risks. Although the majority of such training will be carried out in simulators,some scenarios are more eVectively dealt with through the classroom environment. In addition, the specificemergency procedures for major aeroplane types are determined by the manufacturer and are usedworldwide, with minimal local variation, during training for that type.

7. Training for emergencies requiring immediate actions to be performed from memory, for exampledouble engine failure on a twin-engined aeroplane, are generally required to be practised more frequentlythan other emergencies. Normally, a simulator scenario for this type of emergency would commence at analtitude much greater than that achieved by the Hudson River accident aircraft when it suVered the loss ofpower. This allows those immediate actions that must be performed from memory, and the subsequentchecklist actions, to be put into eVect, and the relighting of at least one engine to be attempted. There is norequirement in the USA or Europe for a landing with no power to be practised. This is mainly becausesimulators are not capable of reproducing water landings (ditchings) with fidelity, as the data to enable thisis not available. However, the procedures for landing (either on water or on land) with no engine power aregenerally trained in the classroom.

February 2009

Supplementary memorandum from the Civil Aviation Authority (AIR 33B)

1. Following the CAA’s appearance before the Committee on 22 April, the CAA is pleased to provide thefollowing additional information, requested by the Committee, which we hope will be helpful to the inquiry.

Whether the CAA is a statutory consultee in planning applications to change airports into diVerent alternativeuse (Qq 552–557)

2. Section 19 and Schedule 2 of the Civil Aviation Act 1982 makes provision for the CAA to be a statutoryundertaker for a number of purposes, none of which includes the purpose described by the Committee. Inaddition, planning legislation sets out a number of consultation requirements for developments, but againthe CAA is not a statutory consultee for the purpose described. However, the CAA would be made awareif a licensed aerodrome was to cease to be an aerodrome because the licensee would be required to surrenderthe licence.

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Ev 210 Transport Committee: Evidence

3. The Department for Communities and Local Government has recently concluded a publicconsultation on a list of statutory consultees for National Policy Statements. The consultation included aproposed Statutory Instrument—Infrastructure Planning (National Policy Statement Consultation)Regulations 2009—which will include the CAA as a consultee where any National Policy Statement relatesto airports. The CAA supported its inclusion on the list.

May 2009

Memorandum from M I Rushton, Cambridgeshire (AIR 35)

I would like to submit my concerns over proposed changes to flight paths in this area.

My great concerns are:

— Safety issues: which would arise due to any increase in air traYc in an area already coping withconsiderable military aircraft.

— Intolerable noise levels: where not only would residents, but also the racing industry, be aVectedbadly.

— Alternatives are available: ie using space over the sea where quality of life to people living belowwould not be aVected.

— Concern as to whether UK airports can safely handle much greater volumes of passengers thanthey do already, especially at a time of environmental issues.

— I can only see the balance of conflicting interests being struck by compromise, financial and growthmatters not always being allowed to destroy others peace and tranquility.

October 2008

Memorandum from the Airport Operators Association (AOA) (AIR 36)

1. Introduction

This response to the House of Commons Transport Committee’s invitation to submit evidence on itsInquiry into the use of airspace is submitted by the Airport Operators Association (AOA), the trade bodythat represents the interests of and speaks for British airports. AOA’s membership is drawn from a widerange of British airports and includes all of the nation’s major international and regional airports and asignificant number that operate in the field of business and general aviation. A listing of our membership isattached at ANNEX 1.

2. Summary

— AOA believes that the forecasts presented in the 2003 Future of Aviation White Paper continue tobe valid;

— Greater strategic interplay between military and civil airspace is required with a key componentbeing the critical examination of “ownership” of airspace and the potential release of militaryairspace for civilian commercial use;

— The development of a UK Airspace Master Plan is essential;

— The present framework for airspace development is demonstrably piecemeal;

— The current framework for consideration of airspace changes in the civil sector containscomprehensive environmental impact and stakeholder engagement provisions;

— All UK aviation stakeholders, legislators, regulators, air navigation service providers, airspaceusers and airports, must support the development and implementation of the Single European SkyATM Research (SESAR) programme and by doing so contribute to the new technologies andtechniques that will be delivered;

— SESAR presents the opportunity for a pan-European solution to address the current fragmentednature of airspace over Europe and thereby to facilitate greater eYciencies in the system and enablecapacity for the forecast demand in air transport to be met;

— Consistent with the work being undertaken in SESAR there has to be a more co-ordinatedapproach to the planning and design of airspace in the UK with a clear understanding of the rolesand responsibilities of entities such as CAA, DAP and DfT;

— AOA considers that Government should be responsible for the funding of the structuredprogramme for the redesign of UK airspace but that changes or developments within thatredesigned framework should be funded by the party proposing the change or development;

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— There are issues that have airspace impacts and are of particular concern to airports but which arenot being addressed by the Committee’s Inquiry. These include the development of windfarms inthe local airspace under the control of airports and the potential impacts on air traYc control radarand aircraft approach procedures. These issues are of significant safety concern;

— In addition, there are current proposals developed by Ofcom for radio spectrum pricing which will,if implemented, impose significant costs for the provision of essential aviation safety systems e.gapproach radar and approach navigational aids. As the Ofcom proposals potentially impactoperations within local airport airspace we consider it appropriate to mention it in this response.

3. Responses

“What changes to the management of airspace could be required as a result of the additional airport capacityoutlined in the 2003 White Paper? Are the White Paper’s projections for increased passenger demand stillaccurate? Are all the measures to provide increased passenger demand likely to be implemented?”

3.1 AOA continues to believe that the forecast increases in passenger demand over the period to 2030 aspresented in the 2003 White Paper are valid despite current economic circumstances which are likely to havea short term impact. Furthermore, we believe that these forecasts will be reflected in the development ofairport capacity to meet that demand.

3.2 The 2003 White Paper notes that the additional airport capacity required to meet that forecastdemand “must be matched by a corresponding increase in airspace capacity”. However, despite the WhitePaper’s aims for a structured programme for the redesign of UK airspace being brought forward by the CAAthere has been little obvious movement towards this objective. The development of airspace would appearto continue to be progressed on a somewhat piecemeal basis.

“Can safety be maintained as airspace is increasingly utilised? Is there suitable interface between military andcivilian arrangements for air traYc control?”

3.3 Safety within aviation always has to be maintained at the highest possible levels and AOA is confidentthat the exceptional record of all of the stakeholders in the UK aviation industry will ensure that these highstandards are maintained and enhanced as time progresses and traYc increases.

3.4 At the operational level there is an eVective interface between military and civilian air traYc control.However, we do not consider that this interface is necessarily maintained at the strategic level, particularlyin relation to “ownership” of airspace and any strategic initiatives to facilitate the of release military airspaceto the commercial civilian sector. If such airspace could be released on a permanent basis, it would enablecivilian flights to make use of that additional capacity and potentially facilitate more direct routings, whichwould have environmental benefits through reduced fuel burn.

3.5 The Committee will be aware that the military does allow short term release of some of its airspaceeg at weekends. However, these short term fixes, whilst useful, do not provide the long term airspace capacitygains that would be greatly welcomed by commercial aviation.

3.6 An issue which is very important to UK airports and air navigation service providers (ANSP), is theforecast future critical shortage of qualified air traYc control oYcers. This is an issue which could haveserious repercussions for the future development of UK aviation as a whole if it is not addressed. One usefulconstituent to an overall approach to this issue would be a review of the current lengthy and expensive“conversion” arrangements required for military controllers wishing to become controllers in the civil sector.

“Is the current approach to planning and regulating the use of airspace adequate? Would an Airspace MasterPlan covering the period of the White Paper be beneficial? Could a piecemeal approach to individualdevelopments necessitate additional redesigns subsequently?”

3.7 The responsibility for planning and regulating airspace lies with the Civil Aviation Authority andmore specifically its Directorate of Airspace Policy (DAP). While we believe that DAP is an eVective airspaceregulator we also believe that there is little evidence of it developing the inclusive “structured programmefor the redesign of UK airspace” as envisaged by the 2003 White Paper. In the five years since the publicationof the White paper, AOA has not been invited, as the representative body for UK airports, to field anyexperts to contribute to this much needed work.

3.8 AOA fully supports the development of a UK Airspace Master Plan covering the period of the WhitePaper and beyond. Indeed, such a Master Plan could complement the work being undertaken in Europe onthe SESAR initiative (covered in more detail in paragraphs 3.15 to 3.23 inclusive). A Master Plan wouldprovide a structured framework within which airspace development could be progressed and implementedand with a presumption in favour of such developments.

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Ev 212 Transport Committee: Evidence

“How are the eVects and aircraft noise and emissions taken into account when changes are made to the use ofairspace? Who should be consulted about such changes? How should the balance between conflicting interestsbe struck?”

3.9 Airspace change proposals are supported by a CAA document, CAP 725 Airspace Change ProcessGuidance. This document was initially published in 2002 but has been updated as since that time “publicinterest in aviation-related environmental matters has greatly increased, in part prompted by theGovernment’s Air Transport White Paper in December 2003. At local level, noise and emissions haveemerged as significant issues…”40. Accordingly, environmental considerations play a key part in anyproposal to introduce or change airspace.

3.10 Appendix B to CAP 725, Airspace Change Proposals—Environmental Requirements states:

“The Civil Aviation Authority (Air Navigation) Directions 2001 (incorporating VariationDirection 2004) (HMG, 2001) requires the CAA to take into account “the need to reduce, controland mitigate as far as possible the environmental impacts of civil aircraft operations, an inparticular the annoyance and disturbance caused to the general public arising from aircraft noiseand vibration, and emissions from aircraft engines”. And “It is the function of this document toassist those preparing airspace change proposals in providing suYcient environmental informationfor public consultation and to inform the decision making process”.

3.11 CAP 725 requires airspace change proposals to be supported by:

— A description of the airspace change;

— TraYc forecasts;

— An assessment of the eVect on noise;

— An assessment of the change in fuel burn / CO2;

— An assessment of the eVect on local air quality;

— An economic valuation of environmental impact.

3.12 In terms of public consultation, CAP 725 requires the proposer of the airspace change to identify“all of the diVerent parties aVected by the design options”41 and to have undertaken a stakeholder analysisto ensure that it can be demonstrated that a complete consultation on the proposal has taken palace.

3.13 Regarding the balancing of conflicting interests, CAP 725 states:

“Consensus is not necessary nor should it be expected. However, a Change Sponsor will beaccountable for their decisions to either accommodate or disregard consultees’ responses and forproviding timely feedback to the consultees. These decisions will be scrutinised and form part ofthe Directorate’s (DAP’s) assessment criteria at the Regulatory Decision stage.

AOA considers that CAP 725 provides comprehensive and proper provisions in relation toenvironmental issues arising from proposals to introduce airspace changes and to take account ofthe views of the general public and other stakeholders in the proposal consultation process.”

“How does the management of airspace in the rest of Europe aVect flights into the UK? Is there an opportunityto integrate our plans for changes to airspace management more eVectively with those of other Europeancountries?”

3.15 It is widely acknowledged that airspace over Europe is highly fragmented having developed largelyaround State geographic borders / boundaries. This fragmentation does not provide for a high level of airtraYc management (ATM) eYciency and unless it is addressed the system will become more congested astraYc continues to grow.

3.16 As a direct result of the need to completely reconsider how European ATM will deal with the futuredemands for sustainable growth in air transport, the SESAR (Single European Sky ATM Research)initiative was introduced. For the first time in European ATM history an ATM improvement programmeinvolving all of the aviation stakeholders (civil and military users, ANSPs, airports, aerospacemanufacturing, regulators and legislators) has been launched with the objective of achieving a “paradigmshift” through a pan-European approach to the planning and delivery of European ATM and in support ofSingle European Sky legislation.

3.17 The first phase of the SESAR project was completed in March 2008 with the production of an ATMMaster Plan which will form the basis of the project’s next phase, the Development Phase, to be completedby 2013. The intention is that the ATM Master Plan will be a living document which will be updated asprogress is made.

3.18 SESAR is the only pan-European ATM development programme and it will only succeed indelivering its objectives through the commitment of all of the ATM stakeholders. To date the CAA, DfT,NATS, UK airports and some airlines have been directly involved.

40 CAP 725 CAA Guidance on the Application of the Airspace Change Process—Foreword41 CAP 725 CAA Guidance on the Application of the Airspace Change Process, Page7, Paragraph 14

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3.19 The SESAR objectives are extremely challenging:

— A three fold increase in capacity which will reduce delays both on the ground and in the air;

— Improve safety performance by a factor of 10;

— A 10% reduction in the eVect that flights have on the environment;

— A reduction of at least 50% in the cost of providing ATM services to airspace users.

“What opportunities are there to apply new techniques and technologies to reduce wasteful flying on indirectroutes and excessive “stacking” while planes wait to land? How can the potential of any such opportunities bestbe realised? Could environmental benefits be gained as a result of such improvements?”

3.20 Fundamental to the success of SESAR is the development and application of new technologies andtechniques and as such a huge eVort is going into the necessary research and development that will enablethese factors to be delivered. Associated with many of these applications is the need to deliver quantifiableenvironmental improvements in all phases of flight.

3.21 The aviation industry is however not sitting back and waiting for SESAR to make things happen.New air traYc control techniques including Continuous Descent Approaches (CDA) are being introducedat some airports which deliver benefits including reduced noise, less disturbance to local residents and lowerfuel burn. In addition, airports generally are highly pro-active in promoting and delivering environmentalmitigation and improvement schemes, many in consultation with their community stakeholders.

3.22 The work undertaken in SESAR is already starting to demonstrate how new ATM techniques andarrangements may provide benefits. Initiatives such as Collaborative Decision Making (CDM) will delivereYciency gains by improving the processes whereby airports, ANSPs and airspace users interact and therebydeliver environmental benefits through less unnecessary fuel burn both on the ground e.g by more eVectivetaxiing; and in the air through more direct routings and sequenced operations that reduce the need to“stack”.

3.23 The flexible use of airspace will also enable capacity gains to be achieved as will the use of militaryairspace. Furthermore, the development of Functional Airspace Blocks (FABs) between neighbouringStates will reduce the fragmentation of airspace over Europe and deliver improved ATM eYciency.

“In relation to the redesign of UK airspace of the roles and responsibilities of each of the interested parties—Department of Transport, the CAA, airport operators, NATS, etc—appropriate and clearly understood? Arethe structures of the parties appropriate for undertaking the roles that they should play?

3.24 AOA has some concern that the roles and responsibilities for airspace redesign are not particularlywell defined or understood. DAP is undeniably acts as an airspace regulator but there is no obvious evidencethat DAP is undertaking the function of a strategic planner of airspace as envisaged by the Government inthe 2003 White Paper.

3.25 Many AOA member airports consider that the overall process for airspace capacity and planningdoes not work well. It is piecemeal, as previously stated, is protracted in terms of process and createsdiYculties for airports in planning their development plans.

“Do airspace management considerations delay the planning processes in relation to airport developmentproposals? How will airspace management considerations be taken into account by the proposed newInfrastructure Planning Commission and the relevant National Policy Statements on airport planning?”

3.26 Airspace management can impact airport development proposals. While it is diYcult to be definitiveon this issue it is possible that an airport’s development plans may include and, to some degree, be dependentupon changes to its airspace.

3.27 A more fundamental issue is that of airspace capacity and the impact that deficiencies in capacitywill have on the ability of airports to eVectively bring forward development proposals to meet their plansto cope with increased demand for air transport services. Airspace is this respect becomes a key factor in theoverall capacity equation.

3.28 AOA is not aware of how airspace considerations will be taken into account by National PolicyStatements on airport planning. What is required is a National Policy Statement on airspace and theproduction of an Airspace Master Plan.

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Ev 214 Transport Committee: Evidence

“What could be the implications for smaller airfields, recreational flying and helicopters of changes to airspacemanagement to enable safe and eYcient increases at the UK’s major airports? How should an appropriatebalance between conflicting priorities be determined?”

3.29 It is undeniable that changes to airspace management to enable capacity gains at major airportscould impact upon the stakeholders referred to in this question. However, as stated above (paragraphs 3.9to 3.14 inclusive) CAP 725 provides a comprehensive framework for consideration of such airspace changesand allows for all stakeholders and parties aVected by the proposed changes to be fully consulted. This CAPalso includes appropriate provisions whereby conflicting priorities can be addressed.

3.30 It is also perhaps noting that the airports industry has been central to the development of a safetyframework for flying undertaken outside of controlled airspace—Air TraYc Services Outside of ControlledAirspace (ATSOCAS). This framework is primarily for the benefit of general aviation and recreational flyingoperated from small aerodromes. The ATSOCAS service is provided at no cost to the users ofuncontrolled airspace.

“Will it be possible to recruit and train staV in order that airspace changes can be implemented in parallel withadditional airport capacity?”

3.31 This question has two basic components ie airspace design and air traYc control management.

3.32 In terms of airspace design, there is a shortage of qualified designers in the market with the primaryresource coming from parties that were once employed by DAP when it used to provide an airspace designservice. While there is little evidence that this level of approved design supply is causing current problems,but this may change over time.

3.33 Once changes have been approved they have to be implemented and this is where the requirementfor air traYc control staV to manage the revised airspace comes into play. As previously stated, there is acritical forecast shortage in the supply of qualified air traYc control oYcers and while automaton and newtechnologies may address some of this anticipated shortfall there remains a clear need to find means wherebysupply can match demand. This will involve additional training resources and initiatives such as making thetransition from military to civilian air traYc control more streamlined and less diYcult.

“Who should fund airspace changes? Is there likely to be enough funding to undertake the redesign required tobring about the necessary additional airspace capacity?”

3.34 AOA believes that the responsibility and funding for the development of a structured programmefor the redesign of UK airspace as proposed in the 2003 White Paper should lie squarely with Government.While execution of this process would lie with CAA the costs should not be included in CAA’s charges toairspace users and airports.

3.35 Insofar as funding individual airspace change proposals e.g at airports, AOA considers that it isappropriate for such costs to be the responsibility of the change proposer. In this regard it will be for theproposer to determine and source the funding to progress and implement the airspace changes envisaged.

October 2008

Annex 1

AOA AIRPORT MEMBERS

BAA Aberdeen Airport Ltd

BAA Edinburgh Airport

BAA Gatwick Airport

BAA Glasgow International Airport

BAA Heathrow Airport

BAA Plc

BAA Scotland

BAA Southampton International Airport

BAA Stansted Airport

Barra Airport

Belfast International Airport

Benbecula Airport

Birmingham International Airport

Blackbushe Airport

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Transport Committee: Evidence Ev 215

Blackpool International Airport

Bournemouth Airport

Bristol Filton Airport

Bristol International Airport

Cambridge City Airport

CardiV International Airport Ltd

Carlisle Airport

Chester Hawarden Airport

City Airport Manchester

City of Derry Airport

Coventry Airport

Denham Aerodrome

Dundee Airport

Durham Tees Valley Airport

East Midlands Airport -Nottingham, Leicester, Derby

Elstree Aerodrome

Exeter International Airport

Fairoaks Airport

George Best Belfast City Airport

Glasgow Prestwick International Airport

Gloucestershire Airport

Guernsey Airport

Highlands and Islands Airports Ltd

Humberside International Airport

Infratil Airports Europe Ltd

Inverness Airport

Isle of Man Airport

Jersey Airport

Kemble Airport

Kent International Airport-Manston

Kirkwall Airport

Leeds Bradford International Airport

Liverpool John Lennon Airport

London Ashford Airport (Lydd)

London Biggin Hill Airport

London City Airport

London Farnborough Airport

London Heliport

London Luton Airport

London Southend Airport

Manchester Airport

Manchester Airports Group plc

Newcastle International, Airport

Newquay Airport

Norwich International Airport

Oxford Airport

Peel Airports Ltd

Redhill Aerodrome

Regional Airports Ltd

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Ev 216 Transport Committee: Evidence

Retford (Gamston) Airport

Robin Hood Airport Doncaster SheYeld

Shoreham Airport

Stornoway Airport

Sumburgh Airport

Sywell Aerodrome

TBI Plc

Thruxton Airport (Western Air ) Ltd

Tiree Airport

Warton Aerodrome

Wick Airport

Supplementary memorandum from the Airport Operators Association (AOA) (AIR 36A)

REQUEST FOR INQUIRY: OFCOM PROPOSALS TO INTRODUCE SPECTRUM PRICING FORAVIATION AND SHIPPING

The Airport Operators Association is the trade association that represents the UK airports industry. Inour submission to your committee’s recent inquiry into the use of airspace we commented on Ofcom’sproposals to introduce Administered Incentive Pricing (AIP) for the use of aeronautical and maritimespectrum.

Our members, along with other aviation users, have significant concerns with the proposals being set outby Ofcom.Aviation’s use of spectrum is mandated internationally, under the Chicago Convention (1949). Both ICAOand the World Radio Communications Conference (International Telecommunications Union) have a rolein setting internationally agreed spectrum allocations for aeronautical use. Changes in these allocationscannot be imposed or changed by one state acting unilaterally.

AIP will introduce a significant new cost to the aviation industry- AOA has found that an airport the sizeof Birmingham would pay between £800,000 and £1,100,000 per annum. NATS En Route would also havea significant liability. This cost is coming at a time where, as demonstrated by the failure of XL, the industryis under significant financial pressures.

Some airports will, given their profitability, be presented by significant costs from AIP. In the case ofHumberside these costs would represent almost half of its profits. Inverness airport, which is currentlyowned by Highlands and Islands Airports Ltd (itself owned by the Scottish Government and operated toprovide lifeline services in the north of Scotland), would see its losses increased by a further sixth. This wouldimpose a cost on the taxpayer for little discernable gain, whilst diverting funds currently used for the benefitof those taxpayers.

AIP will bring with it potential environmental disbenefits. The money raised from the industry by AIPwould be unavailable for investment in technological and operational changes to allow UK aviation tobenefit from the changes being made at a European level by SESAR and SESII. In the longer term this willreduce the ability to UK aviation to increase the capacity of controlled airspace, to shorten routes, and tominimise the environmental impact of aviation through more eYcient flight controls.

There is also a safety aspect to these proposals. Ofcom has argued that as the use, or carriage, of safetyequipment is mandatory for some aircraft and airports it would be impossible for AIP to bring about adetrimental impact on safety.

Some parts of the aviation system are not subject to mandatory safety requirements—particularly thegeneral aviation sector. Introducing an elective cost on the use of VHF and navigational aids and some GAflyers will vote with their feet: foregoing VHF systems on their aircraft, and flying from unlicensedaerodromes which aren’t subject the CAA’s rigorous licensing criteria. This could represent a materialdetriment to safety.

A final concern is that Ofcom is eVectively going beyond the recommendations of the Cave Audit, whichwas accepted by the government as the basis of its policy on spectrum charging.

The 2005 Cave Audit of spectrum recommended the application of AIP to “public-sector” spectrum usesin order to establish a market mechanism to encourage the more eYcient use of that spectrum. It was,however, noted that:

“If there is judged to be no prospect of alternative use due to international restrictions and sincethe UK is unable to act unilaterally in spectrum that is internationally harmonised for on-boarduse, then the opportunity cost of the spectrum for alternative use should be judged to bezero.”(Cave Audit p.56)

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Ofcom has signally failed to demonstrate what spectrum eYciencies it believes the introduction of AIP toaeronautical uses will bring, given the largely international nature of aeronautical spectrum allocations. Asproposed, AIP fails to recognise the essentially international nature of aviation spectrum use. Instead it seeksto impose a market mechanism where Professor Cave’s review of spectrum management argued there canbe no market.

Given the nature, timing, and potential consequences of these proposals for aviation (as well as themaritime sector), AOA believes that is a subject that deserves scrutiny by the Transport Select Committee.

December 2008

Supplementary memorandum from the Airport Operators Association (AOA) (AIR 36B)

Further to the appearance of representatives from BAA, Birmingham International Airport, London CityAirport, Manchester Airport and AOA before the Transport Committee on 1st April, we were asked tosubmit supplementary evidence on matters relating to Continuous Descent Approaches (CDA) and AOA’sposition on the Competition Commission’s views on the competition between airports, specifically in thesouth east of England in the context of the recommended sales of Gatwick and Stansted Airports.

The data on the percentage number of CDAs flown at Heathrow, Gatwick, Birmingham and Manchesteris as follows:

Year Heathrow Gatwick Birmingham Manchester

2004 83% 77% " "

2005 82% 78% " "

2006 84% 80% " 74%2007 83% 80% " 76%2008 82% 83% 87% 80%

Further analysis of the month by month figures contributing to these annual percentages can be presentedif desired.

Because of the complexities of the operational approaches at London City Airport no CDA analysis isavailable.

In respect of the recommendations of the Competition Commission, it has to be understood that givenAOA’s remit to represent all British Airports, the scope of any position AOA holds is limited strictly togeneral assumptions about how we see competition in the UK airports market in general. As a rule we donot take positions on questions of ownership of our member airports. Our remit is to make representationson behalf of our members on public policy issues where they hold a common interest. Although theCompetition Commission’s recent activity regarding BAA might be considered to have public policyinterest, in our case it is clear there is, as I stated to the Committee on 1 April, no common position amongour members.

However, we do have views on the Competition Commission’s perception of the UK airports market asa whole. We attach great importance to the recognition that UK airports operate in a climate, where theycompete with each other, and airports in Europe, for airline routes and passengers. During the framing ofthe recent EU Airport Charges Directive, AOA invested a great deal of time working with EU opinionformers to explain the uniquely liberal nature of the UK’s market in air transport, which includes themajority of British airports. As a result, airports (and their passengers) have partially avoided a costlyDirective that would have brought little benefit. It is extremely important to us that this hard wonrecognition remains foremost in the minds of those influencing both UK and EU policy in this general area.

April 2009

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Ev 218 Transport Committee: Evidence

Memorandum from the Omega Academic Partnership of UK Universities (AIR 37)

Summary

— The Omega42 Partnership is working in several areas to characterise ineYciencies in the airtransport system and to oVer knowledge to the sector and Government to enhance performance:air traYc management (ATM) eYciency is included in the scope of work.

— Contextual studies are underway on environmental topics that bear upon the management ofairspace. These include the possible implications upon future flight patterns from maturingknowledge on contrail and induced cirrus cloudiness, the eVects of more fuel eYcient enginetechnologies upon ATM through possible slower and lower flight and the eVects of diVerentialcharging regimes for airspace use upon route mileage.

— One particularly relevant Omega study is focussing on ineYciency within the European air traYcmanagement system and assessing how to improve its environmental performance in the future.EVective international integration of advanced aircraft and ground technologies, enhanced airportand airspace capacity and “green” operating procedures are of paramount importance. Even withimproved ATM performance, total environmental impacts of aviation are likely to increase due totraYc growth, and hence incorporating aviation into an eVective emissions trading system is animportant consideration.

Omega Partnership Work on Aviation Sustainability

1. This submission is oVered by the Omega academic partnership of UK universities. The substance ofthe document is output from Omega work undertaken by the University of Cambridge examiningineYciencies in the air traYc management system that incur environmental penalties. The Omegapartnership, funded by Government, develops and transfers knowledge that can improve the long-termsustainability of the air transport sector.

2. At a time of heightened concern about the climate impacts of aviation, there is a strong imperative toreduce ineYciencies in the ATM system and so save fuel and CO2 emissions. ATM issues have an importantrole in environmental impact mitigation because they have an impact on all the aircraft within the system.Future ATM designs may be influenced by the development of understanding about impacts and also byenvironmentally-motivated technology changes. As delivery of ATM improvement solutions is far fromspeedy, it is appropriate to flag some of the environmental issues that may aVect the functionality of thesystem over the coming decades.

3. The scientific community continues to examine the climate impacts of aircraft contrails and inducedcirrus cloudiness. Current expectations are that it may be up to 10 years before knowledge on this issue issuYciently mature to say whether the eVects require any diVerent technological or operational response.However, there remains the possibility that operational practice in relation to cruise altitudes or flighttrajectories might need to be altered to suppress the formation of contrails. That would, in turn, haveimplications for aircraft design. In such circumstances, there would be major implications for the controland capacity of airspace use. Omega supported work in this area, to review the state of knowledge, is aboutto be reported.

4. Fuel and CO2 pressures are critical drivers for technologies being considered for future aircraft designs.With the prospect of single aisle replacements for the B737 and A320 aircraft families in about a decade,serious consideration is being given to powering such aircraft with “open rotor” power plants. Thesignificance of this issue for ATM is that aircraft powered by such engines may fly slower and lower. Asidefrom the acceptability of such technologies to the traveller (and to airport communities given that “openrotor” powered aircraft may be more noisy than shrouded fan engines), there are ATM implicationsassociated with part of the aircraft fleet operating in a diVerent manner and how it would be integrated witha “traditional” jet fleet in ATM terms. Omega is currently examining the projected noise performanceassociated with this technology, the scope to reduce it to acceptable levels and the trade-oVs between noiseand emissions. The study will be reported in December and will feed into developing industry thinking onthe viability of “open rotor” engine technology.

5. A further issue currently being examined by the Omega partnership is the environmental penaltieslinked to diVerential charging for use of airspace in Europe. Anecdotal evidence suggests that significantexcess mileage is flown on some routes in Europe in order that airlines can avoid more expensive national

42 Omega is a one-stop-shop providing impartial world-class academic expertise on the environmental issues facing aviation tothe wider aviation sector, Government, NGOs and society as a whole. Its aim is independent knowledge transfer work andinnovative solutions for a greener aviation future. Omega’s areas of expertise include climate change, local air quality, noise,aircraft systems, aircraft operations, alternative fuels, demand and mitigation policies.Omega draws together world-class research from nine major UK universities. It is led by Manchester Metropolitan Universitywith Cambridge and Cranfield. Other partners are Leeds, Loughborough, Oxford, Reading, SheYeld and Southampton.Launched in 2007, Omega is funded by the Higher Education Funding Council for England (HEFCE).www.omega.mmu.ac.uk

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Transport Committee: Evidence Ev 219

airspace charging areas. With a view to informing the European debate on more eYcient use of airspace,Omega is seeking to quantify the excess mileage and associated emissions penalties arising from this practice.Results will be available in early 2009.

Response to Transport Committee Questions

6. This submission primarily addresses the main environmental question posed by the TransportCommittee—What opportunities are there to apply new techniques and technologies to reduce wastefulflying on indirect routes and excessive “stacking” while planes wait to land? How can the potential of anysuch opportunities best be realised? Could environmental benefits be gained as a result of suchimprovements?

7. In an ideal world, all aircraft would fly optimal trajectories between airports, comprising the mostdirect route (accounting for wind), at their most fuel-eYcient altitude and speed. This would lead to lowestCO2 emissions, as well as reducing most other environmental impacts if designed appropriately. However,real world constraints lead to aircraft flying less eYcient trajectories and hence at greater environmentalimpact than is ideal. The practicalities of the air traYc management system directly influence the trajectoriesthat aircraft can fly, and hence improvements to the ATM system oVer the potential for better environmentalperformance of all aircraft within a given region. The often-cited Intergovernmental Panel on ClimateChange (IPCC) 1999 report “Aviation and the Global Atmosphere” suggested that improvements in ATMcould help to improve overall fuel eYciency by 6–12% per flight. But it is only fairly recently that there hasbeen a concerted eVort to understand where these eYciency gains could be obtained, and what theirenvironmental impacts would be, not only in terms of fuel burn, but also noise and local air qualityemissions. For the past two years, the University of Cambridge has been analysing global flight data (andmore recently as part of an Omega study with a focus on Europe) to (a) understand ineYciency levels inATM and verify the accuracy of the IPCC estimate; (b) decompose the overall ineYciency levels into causesin order to better understand how they might be reduced; (c) determine how future ATM systems could bedesigned to address the causes of ineYciency, and (d) assess the overall environmental impacts of possibleATM evolutions. The current findings in each of these areas are pertinent to the question raised by theTransport Committee, and are summarised briefly below.

8. Overall flight ineYciency levels: there are a number of ways of measuring flight ineYciency (eg excessdistance flown beyond the shortest (great circle) distance, extra fuel burn beyond fuel-minimum, etc.). Theformer, although not ideal, is the simplest form and is currently used by Eurocontrol as their ATMperformance metric, so is mostly used here (current on-going analysis is using the superior fuel-based metric,but it is more complex). The University of Cambridge global flight data analysis suggests that overallineYciencies of 12–14% excess track distance per flight are realistic for flights within Europe and the US.Flights within lower traYc regions such as Australia and Africa generally have smaller excess track distancecharacteristics of 4–8% (most likely due to lower traYc densities). Flights through some inter-continentalregions have similar ineYciency characteristics (eg North Atlantic flights), while others can exhibit muchlarger ineYciency levels (eg over 20% for some Europe to South East Asia flights which can equate to anadditional 1000 nm being flown relative to the shortest route). Given that flights within Europe and the USaccount for around 50% of flights, the characteristics of these regions dominate the global ineYciencycharacteristics. Using the simplification that excess flown distance is proportional to excess fuel burn, theIPCC estimate appears somewhat low. Some of this discrepancy may be due to the increase in traYc betweenthe 1990s IPCC estimate and the 2005–08 analysis discussed here and the fact that not all of the extra trackdistance observed can be directly attributable to ATM, as discussed next.

9. Causes of flight ineYciency: the causes of flight ineYciency can be considered to be any factor thatcauses an aircraft to fly a trajectory diVerent from its “four-dimensional” optimal (ie latitude/longitudeground track, vertical profile, speed profile). This includes indirect routes and holding/stacking mentioned inthe question posed by the Committee, plus many other elements as shown below and discussed further next.

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Ev 220 Transport Committee: Evidence

10.

OriginTerminalAirspace

DestinationTerminalAirspace

EnrouteAirspace

Restrictedairspace

Adverse weather

Departureprocedures

Arrivalprocedures

Holding & Vectoring

Standard routes

& Flight Leve

lsExpensive

airspace

Departure fix

Arrival fix

Congestedairspace

11. On take oV, ineYciencies can be introduced by the departure procedures that often require aircraft tofly specific paths and profiles for noise abatement and/or traYc separation purposes. Aircraft may also haveto leave the origin airport terminal area over specific departure fixes which link with appropriatedownstream air routes but which may require non-optimal climb profiles and/or a longer flight path withinthe terminal area compared to a more direct route. In the enroute airspace, standard (and often sub-optimal)air routes and flight levels are typically used and aircraft often fly around regions of restricted or congestedairspace, as well as adverse weather. On approach to the destination airport, aircraft typically enter theterminal area via an arrival fix which may also require non-optimal descent trajectories. If there is airportcongestion, aircraft may need to enter holding stacks or be “vectored” (given heading changes to lengthenor shorten their flight tracks) for separation purposes. Finally, the lateral and vertical elements of the arrivalprocedure will likely be constrained by the need to space, merge and sequence traYc for landing which mayforce them away from their optimal approach procedure. Our studies indicate that, in the current US ATMsystem, the biggest contributor to excess flight distance is standard routings, accounting for about 30%. Thenext biggest contributors are holding/vectoring in the destination terminal area and standard arrivalprocedures, each accounting for around 20% of extra track distance on average. Congested airspace, adverseweather and standard departure procedures each accounted for about 10% of the extra track distance flownon average. Because the characteristics of the European air transportation system are similar to the US, theserelative contributions to excess flight distance can be considered representative of Europe too.

12. Implications for future ATM designs: the findings discussed above give pointers towards appropriatepriorities for future ATM designs to reduce flight ineYciency. The biggest contributor was observed to bestandard routes and restricted airspace (they are combined due to the fact that standard routes were observedto accommodate many airspace restrictions). This ineYciency could be improved through operatingparadigms that allow more widespread use of flight away from the rigid airway structure, as proposed inmany “free flight” or user-preferred trajectory concepts (including the Single European Sky ATM Research(SESAR) initiative). There are many studies to assess how this removal of airspace structure aVects the airtraYc control process, and this needs to be carefully considered to maintain safety at high levels. But if suchconcerns can be addressed, these strategies would improve eYciency in both the enroute and oceanicairspace, allowing more direct routes and flight at user-preferred cruise altitudes and speeds which minimisefuel burn. There are also Communication, Navigation and Surveillance (CNS) limitations in enroute andoceanic airspace in many parts of the world. There are moves in the US and Europe to transition away fromthe legacy system design of VHF radio communication, ground-based navigation and radar surveillance tomore sophisticated infrastructures involving datalink communication, satellite-based navigation andaircraft-based automatic dependent surveillance. These technologies should enable ineYciencies in theseregions to be reduced to handle the forecast traYc growth, for example by reducing separation minima.TraYc is growing most rapidly in some parts of the world where the current infrastructure is unlikely to beable to accommodate it (eg India and China). However, it is likely that technological advances and globalATM harmonization eVorts will enable step-changes in CNS capability in these regions instead of the slowincremental evolution observed in the more developed regions of the world where growth has been moregradual. The high ineYciency results observed in the Europe to Asia flights highlight the adverse eVect oflarge areas of restricted airspace which, in long distance flights, can lead to significant extra distance beingflown. Increasing the number of available airways with the ultimate goal of wholesale removal of these largerestricted areas would therefore be highly beneficial, but this may be a political rather than technicalchallenge.

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13. The second most important ineYciency source was observed to be arrival holding/stacking andvectoring. Limited airport capacity causing arrival delay is the root cause of this issue. Planned increasesin airport capacity are unlikely to keep pace with growth in aircraft movements, and hence it will becomeincreasingly important to manage arrival delay in a more environmentally-friendly way. Future conceptsthat involve four-dimensional trajectory management, and tailored arrivals in particular, should greatlyreduce the need for holding and vectoring within the destination terminal area. It would enable delays to bedetermined far in advance of an aircraft’s arrival into the terminal area, allowing a more eYcientaccommodation of delay. For example, by slowing the cruise speed of an aircraft by a few knots on a longdistance flight to manage its arrival into the terminal area at a pre-determined time when it can be acceptedwithout delay is much more eYcient than having aircraft enter the terminal area at an unplanned time, thenholding them until a runway slot is available. Elements of four-dimensional trajectory management arealready deployed in parts of the US, but major eYciency gains could be achieved by system-wide application,as is proposed in the European SESAR and US NextGen concepts.

14. Standard arrival procedures (excluding holding and vectoring) were the next biggest ineYciencysource. The need for alignment of the flight path with the limited set of runway orientation available at anyairport and the need to maintain a minimum separation distance between aircraft to ensure safety impliesthere will always be some excess track distance observed in this phase. However, careful relaxation ofconstraints (such as reduced stabilization criteria and/or separation minima) imposed on standard arrivalprocedure design without compromising safety could help to minimize this contributor to ineYciency. Thesame comments are valid for the standard departure procedures.

15. Congested airspace related ineYciency should also be helped by 4-dimensional trajectorymanagement. However, the relationship between traYc levels (which are likely to continue to increase in thefuture), airspace capacity and congestion-related ineYciency is highly complex and will need furtherresearch.

16. The need to avoid regions of adverse weather is likely to continue into the future to maintainpassenger comfort and safety. However, better forecasting and adverse weather detection to allow aVectedregions to be avoided more eYciently should be possible in the future.

17. Environmental impacts of ATM: the discussions above illustrate that there is significant scope forATM advanced technologies and procedures to improve environmental performance of the airtransportation system. Future plans for European ATM (eg SESAR) incorporate many of theimprovements suggested above which, if implemented in a timely and integrated fashion, should enable perflight reductions in fuel burn and associated emissions due to ATM of up to 10%. Local environmentaleVects of air quality and noise would be helped through initiatives during the take-oV and landing stages offlight that allow aircraft to fly closer to their optimal vertical and speed profiles, eg Continuous ClimbDepartures (CCDs) and Continuous Descent Approaches (CDAs). The objective of a CDA, for example,is to minimise periods of level during the descent and approach phases of flight, thereby keeping aircrafthigher and at lower thrust for longer, reducing fuel burn, emissions and noise impacts. Enabling aircraft todo this during the entire descent and approach phases can reduce fuel burn and associated emissions duringthe descent phase by as much as 50% per flight compared to a standard descent and approach, while peaknoise is also reduced by 3-6 dBA per flight in some regions. More radical techniques at reducing noise duringthe entire approach involve landing further down the runway (currently possible at Frankfurt) and steeperapproach angles (currently performed at London City but only possible for some aircraft types), but thesewould require detailed studies (eg regarding impacts on safety, infrastructure, pilot training, etc.) before theycould be deployed more widely.

18. The major challenge in all of these cases will be improving environmental performance in the face ofgrowing traYc demand. Congestion was identified as an important contributor to flight ineYciency in thecurrent system, and its importance is likely to increase in the future without major capacity enhancements.Capacity is needed on the ground and in the air, through added infrastructure (eg runways and airspace),technological investment and procedural changes that allow more eYcient use of the capacity that isavailable. Even then, the aggregate emissions from aviation are set to increase in the coming decades becausetraYc growth will exceed the possible eYciency gains (even given aircraft technological improvements).Hence, policy measures such as Emissions Trading Schemes which incorporate aviation in an eVectivemanner will have a major part to play in managing the environmental impacts of aviation’s activities.

19. A further question posed by the Transport Committee bears upon environmental performance—Howdoes the management of airspace in the rest of Europe aVect flights into the UK? Is there an opportunity tointegrate our plans for changes to airspace management more eVectively with those of other Europeancountries?

20. Whilst the practical eVects are best characterised by ATS providers, it is worth noting thatenvironmental penalties will accrue from failure to achieve full gate to gate co-ordination. The text providedto the question on opportunities for reducing indirect routing and stacking highlights the importance ofmore eYcient “four-dimensional” management of aircraft trajectories. This can only be achieved throughclose cooperation between all of the agencies involved in handling a given flight. For example,

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Ev 222 Transport Committee: Evidence

accommodating an ideal Continuous Descent Approach (CDA) procedure into London Heathrow wouldrequire careful coordination with French air traYc managers. To obtain maximum environmental benefitfrom the CDA, the flight should be cleared for the approach while still at cruising altitude in French airspace,so the flight crew can determine their optimal start of descent point that enables them to descend the wholeway at minimum engine power. Achieving this, and other strategies for reducing environmental impact, forALL aircraft is a major ATM challenge, but one that the industry should aspire to. It requires alignedstrategies, infrastructure, technologies and procedures across national boundaries, and the SESAR initiativeis tasked with delivering these aspirations within European ATM in the future.

October 2008

Memorandum from Elizabeth M Balsom (AIR 38)

— More flights into Heathrow airport and the accompanying additional noise will bring a severedeterioration on the quality of life of those of us under the flight path.

— We already experience planes coming in at 2000 ft every 82 seconds for half the day, a constantceiling of sound. Planes all day would be intolerable.

— Aircraft noise starts at 4.40am; the last planes go over around 10.45pm-11pm. As I try to sleep,what am I supposed to do? Lie back and think of England?

— There is no such thing as a quiet aircraft. Claims to the contrary are nothing but biased spin. Thenoise is disturbing inside; outside you cannot hear yourself speak.

— The amount and intensity of aircraft noise has increased exponentially since I came to Putney in1981; it is oVensive to assume we don’t notice it.

— It is profoundly disquieting that the government is seeking derogation from the EU Air QualityDirective, which will be breached if Heathrow expansion goes ahead. I am very worried about thehealth implications from more planes and increased road transport to the airport.

— There is no way that I, a pensioner with a small fixed annuity can share in the much-vaunted growthin wealth that will allegedly stem from Heathrow expansion.

— There is the distinct possibility that more aircraft noise will have a depressing eVect on propertyprices in aVected areas.

— The government’s arguments for expansion, eg “the financial services sector flies six times morethan other businesses”, would be laughable if the situation were not so grave.

— The consultation exercise has been derisory; no government-organised meetings have been held inaVected areas, no minister has come to justify the degradation to our quality of life; no documentswere distributed by the government to aVected households.

— When Stephen Byers sanctioned Terminal 5 he accepted the recommendation that air traYcmovements should be limited to 480,000 a year, because more would have an unacceptable impacton people over a wide area. How can I trust a government that is reneging on this undertaking?

1. I wish to express my thanks to the Committee for the opportunity to describe what it is like living underthe flight path to Heathrow airport. Although proposed expansion of the airport is not among the topics tobe investigated, the Committee is examining:

“How are the eVects and aircraft noise and emissions taken into account when changes are madeto the use of airspace? Who should be consulted about such changes? How should the balancebetween conflicting interests be struck?”

2. Expansion of Heathrow would involve a major intensification in the use of airspace en route to theairport, with significant implications for those of us already aVected by aircraft noise. There are two aspectsto Heathrow expansion, the third runway and the abolition of runway alternation which gives residentsunder the flight path some hours of peace each day. The news that a decision on the third runway has beenpostponed leaves me profoundly afraid. Heathrow expansionists can achieve their aims in a flash byabolishing alternation, at no cost to themselves, but at irreparable and instant harm to us. The runway willtake longer. I have heard local friends in my age bracket say, “perhaps I’ll be dead [by the time the runwayis built].” Any government should hang its head in shame if its citizens prefer death to enduring its policies.

3. When Stephen Byers gave the go-ahead for Terminal 5 he accepted an inspector’s recommendationthat air traYc movements should be limited to 480,000 a year, because more would have an intolerableimpact on people in a wide area of west and south-west London. Now the government is seeking to increasethis number by many tens of thousands, perhaps more. This is a complete betrayal of trust.

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Transport Committee: Evidence Ev 223

4. Because I am writing as a private individual, my account is personal. I quote dates and times when Ior a neighbour noted distressing noise in an attempt to convey what it is like; bodies like NATS and the CAAhave records of flights, so you will know I am not making it up. I am not alone in the distress aircraft noisecauses; about 3,500 signed up for our MP’s campaign against expansion; the number usually sampled innational opinion polls is around 1,200.

The Impact of Aircraft Noise

5. I bought my house in Putney in 1981. For years aircraft noise was simply not an issue; I barely noticedplanes. In recent years this has changed. Planes are now a very noisy, constant, intrusive aspect of life here.Had I known how things would deteriorate I would have made a life for myself in a quieter part of London.I often hear this from people who came to Putney, Richmond, Barnes, Chiswick years ago and are now veryangry at what has happened to their quality of life. Over the past couple of years four good friends, haveleft this road, citing aircraft noise as among their reasons for leaving. It is not a case of caveat emptor; therules of the game have been changed radically, adversely, unfairly.

6. Indeed, we know the government and expansionists do not take adequate account of the detrimentalimpact of noise: Para 3.35 of the DfT document “Expanding Capacity at Heathrow Airport” states:

“Unlike road or rail projects, we do not currently include the impact of noise as an economic factorin our cost-benefit analysis of aviation projects.”

Might one be so presumptuous as to ask, why not?

The Times reported, 27/11/08:

“BAA, the Spanish-owned airport company, plans to increase the number of flights over severalyears in the hope that those living under the flight path will not notice that noise is spreadingthroughout the day.”

This takes me for a fool, and I find it deeply oVensive. I have news for BAA and the government: we donotice planes overhead at a mere 2000ft; the tailfins are clearly visible. To set this in context, the World TradeCenter was 1350ft. We have become accustomed to the expansionists’ spin that the noise environment hasimproved around Heathrow. It there is one single message that I would like to leave with the committee itis that in Putney, the reverse is the case. There is no such thing as a quiet aircraft.

7. Some examples from 2008:

On July 26 a neighbour recorded 175 planes flying over our houses between 15.00–19.00 when hegave up in despair. This is par for the course, and works out at a plane every 82 seconds. Pleasetake a moment to think about this; it is a lot of planes and a lot of noise. As the noise of one aircraftpasses into the distance, it merges with the next one approaching.

The weekend July 5 & 6 was wrecked because there was not one moment free from aircraft noise.Planes were flying overhead from early morning til after 11.15 pm at night. There was no peace.Lunch on Saturday in my neighbours’ garden was ruined because we could not hear ourselvesspeak as planes continually came in low and loud. The instant one was gone, another heaved intoearshot. Incessant noise at these levels is dementing and, because of the stress it induces, damagingto health. Phil Specter created a “wall of sound” in a recording studio; overflying planes create aconstant ceiling of sound.

June 14 a friend brought her 2 1/2 year old daughter to visit. We went into my garden. To mysurprise, the little girl repeatedly pointed skywards saying “noisy aeroplane”; I had not thought achild would be bothered by the noise, yet an infant who is unaware of the debate about Heathrowwas clearly upset.

8. Please don’t run away with the idea that once you’re inside you’re protected from the noise. I havedouble-glazing, but planes are still audible inside my house. They are particularly disturbing at 10.30-11 pmwhen I would like to go to sleep, and when they come over my house just after 4.30 am. November 19 wasparticularly bad for there seemed to be no break; it was impossible to get back to sleep. At 7 am the noisewas still penetrating. Again I would ask you, please think about this, if the only peace we are allowed is from11 pm to 4.30 am. What am I supposed to do? Lie back and think of England?

9. Even during the day, and inside the house, constant aircraft noise is upsetting. I know the government,BAA and BA are determined to deprive us of our half day’s freedom from noise, and I find it hard tocontemplate this. Some areas of Putney already notice no respite; friends in SW15 1NA complain they aresubjected to constant aircraft noise. Indeed, there are days when I have noticed this myself.

Air Pollution

10. In addition to noise, there is the crucial matter of air pollution which is linked to both aircraft andincreased road traYc to the airport. The EU is attempting to control aviation pollution, but our governmentis seeking derogation from the air quality directive. The directive is presumably there to safeguard our health.It is unconscionable that our government should seek to wriggle out of this duty, thereby putting our health

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Ev 224 Transport Committee: Evidence

at risk. I would be truly grateful if the committee is able to examine this aspect. It is hard to grasp the mindsetof a government which will prevent us buying light bulbs by which you can actually see, apparently in thecause of saving the planet, yet has no qualms about a damaging rise in flights over south-west London.

11. In history marauding conquerors mostly reserve such treatment for subjugated peoples, like theJapanese in China and Korea. But some have no compunction at disregarding the welfare and well-beingof their own people. I do not think it hysterical or exaggerated to recall Stalin, Pol Pot, Mugabe. I cannotbut be concerned about the health implications of breaching the air quality directive. If I were younger orhad children, and were looking into a future of many, many years, I would be very worried indeed. Again,please take a moment to think about this. I consider it a complete breakdown of trust in the government.

Balance between Conflicting Interests: Financial, Economic and Health Implications

12. I am a pensioner with a small fixed annuity; by definition my income cannot rise. The DfT’sconsultation document claims that planes over our heads all day are absolutely necessary to generate “neteconomic benefits of around £5 billion in net present value terms” (summary consultation document, para.1.8) This raises a number of questions. How do the government and Heathrow expansionists plan that thiswealth will filter down to me, given my restricted income prospects? (Chanting the mantra “schools andhospitals” just raises a hollow laugh, by the way.)

13. How do they propose to compensate me for the degradation to my quality of life that will result fromnon-stop aircraft noise? I would very much like an answer, given that I have all of the pain and none of thegain. The Times, 27/11/08, reported Willie Walsh as saying all he heard as the planes fly over is the sound ofcash tills ringing. I hear an intolerable racket, and to express such sentiments is a cavalier disregard for myquality of life.

14. And when all’s said and done, the net £5 billion quoted in the DfT consultation document is prettysmall beer, barely more than a couple of years’ profits from the likes of boring old Unilever. Hardly worthsacrificing the quality of life of hundreds of thousands of people. (The 2M group of local councils representstwenty-one councils, over four million people.)

15. Table 16 on page 176 of the DfT document shows no Wandsworth residents working at Heathrow.So this borough gets the hardship of aircraft noise, but no employment benefits from the airport.

16. The deleterious impact on property prices of more intensive use of the airspace above us is a majorworry. An article based on conversations with leading estate agents by Elaine Moore in the FT, 1/11/08,confirms my fears. She examines factors influencing property prices and writes: “unappealing new features,such as airport developments can knock thousands from a property’s value.” A neighbour told how whenshe was selling her house in Barnes, prospective buyers fled when, as they came up the garden path, planesflew over. They did not bother to look inside. I would be interested to know how the Heathrow expansionistspropose to compensate us for loss in value. Will the government compel them to do so, or will its attitudebe:” Tough. Put up and shut up?”

17. I do wonder at the intellectual calibre of the people who have penned the expansion document. Giventhe turmoil in the financial markets which has brought our economy to the brink of disaster, and which wasprecipitated by the recklessness of sector participants, one might query the DfT’s contention that Heathrowshould be expanded because “the financial services sector uses six times more air travel than otherbusinesses” (Summary Consultation Document, para 1.1) If only these people had stayed home we mightall be a damn sight better oV.I struggle to understand the DfT’s thinking, as exemplified by this quote from the DfT website.

“The Department is conducting an Equalities Impact Assessment (EqIA) to broaden itsunderstanding of the potential impacts of Heathrow’s development on individuals living withinthe 57dBA Leq noise contour, in terms of race, gender, disability, age and social deprivation. ThisEqIA is what the Department is now consulting on.”

What on earth have these factors to do with noise hitting your eardrums from 2000ft? Noise is noise,whatever the colour of your skin. Some of my friends who most resent the destruction of our quality of lifeare men. Fancy that! But my quality of life may be determined by people who come up with this sort ofnonsense. It leaves me very afraid. (My spellcheck oVers “daft” for DfT.)

18. Stephen Byers’ acceptance of the inspector’s recommendation of an annual limit of 480,000 flightsinto Heathrow, in theory, balanced the interests of residents and those of the aviation industry. How can Itrust a government that is now grossly recalculating this balance in favour of the aviation industry to thedetriment of those of us under the flight path? Despite the noise science spinning of the government andaviation industry, planes are every bit as noisy as when Byers set that limit.

19. This year I have visited friends in Bath, Leamington Spa, Liverpool, Plymouth and Worthing. As Isat in their houses I was always thinking: no noise. Why must I be penalised for a decision I made 27 yearsago when Heathrow was not the blight on the environment it now is?

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Consulting those Affected

20. The Committee is asking who should be consulted about changes in the use of airspace. Over the pastyear, during the so-called period of consultation on the expansion of Heathrow, my impression has been thatthe government has been determined not to consult those most aVected. In my view everyone who iscurrently aVected by aircraft noise, plus those who might be aVected in future, should have been oVereddetailed explanations of what lies ahead, for instance, the opportunity to attend presentations by NATS.The channels for objections should have been very clear. Some of the arguments in the consultationdocument, when not totally fatuous, are couched in technical jargon, impenetrable acronyms and illegiblemaps that render them totally inaccessible to most ordinary people; the spinners’ aim is to blind us withscience. We should have had the opportunity to seek face-to-face clarification.

21. Putney is blighted by aircraft noise, but the Government organized no meetings here. Not oneGovernment minister has been here to justify to us depriving us of half a day’s respite from aircraft noiseas they plan to do, nor to justify seeking derogation from the EU air quality directive, which cannot buthave harmful implications for us. No consultation documents, long or short, were distributed here by thegovernment; interested residents had to request the document themselves. A DfT exhibition was held at theWetlands Centre in Barnes, but this is awkward to teach by public transport and I do not have a car. Again,this was not publicised in Putney, but a councillor friend took me. This is where I obtained my copy of theconsultation document.

22. Were it not for the eVorts of Wandsworth Council, the activities of pressure groups like Greenpeaceand HACAN, I would be unaware that a “consultation exercise” had been taking place. Indeed, myimpression is that our government is determined that we should not know what lies ahead.

23. Earlier this year I attended a meeting in Wandsworth Town Hall organised by the council. A womanin the audience said she had attended a meeting with Jim Fitzpatrick led by her MP (Battersea). She reportedthat the minister had discussed the merits of various earplugs. This is the level of government interest inour plight.

24. When Heathrow expansion has been raised at PMQs the incumbent’s response has been arrogantlyindiVerent. At a PMQs session in spring 2004 Jenny Tonge, then MP for neighbouring Richmond Park,asked a question about the noise which those of us under the flight path in southwest London endure. Blair’sarrogant, dismissive demeanour encapsulated the government’s attitude to us. The question had been putcalmly, unconfrontationally, yet she, and thus all of us under the flight path, was tossed haughtily aside. Icannot recall the date, but it sticks in my mind.

12 November 2008 an Ealing MP asked a question about Heathrow expansion. The prime ministerarrogantly dismissed him. When I watch these exchanges, the thought cui bono? runs through mymind, together with the realisation, it’s certainly not me. The decision has been taken and the“consultation” exercise was a farce.

25. Companies like BAA and BA have easy access to the media, where they argue for Heathrowexpansion; likewise bodies funded by the aviation industry like Future Heathrow. It is unfortunate for usthat they do not tell the whole truth. For instance, last September Future Heathrow took a full-page advertin the Financial Times saying “Frankfurt’s got three runways, so we want three”. In making this argumentFuture Heathrow never gives details of the number of people under the runways to so-called competitorairports compared with those under the flight path to Heathrow, located at the west of one of the world’smost densely populated conurbations. Heathrow is quite simply in the wrong place.

26. The government and Heathrow expansionists are riding roughshod over us. I find it cruelly ironic thatit was in Putney that 360 years ago the soldiers of the New Model Army declared: “the poorest he that is inEngland hath a life to live, as the greatest he.” Not if you object to your quality of life being destroyed byaircraft noise. Our only saviour is the East Wind.

December 2008

Memorandum from EUROCONTROL (AIR 39)

In response to the call for written evidence launched by the UK House of Commons TransportCommittee, please find below the EUROCONTROL’s responses regarding your inquiry into the use ofairspace. All the views expressed below are coordinated within the EUROCONTROL Agency and are basedon the latest status of development of our activities. Our responses are in italics below your questions.

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1. What changes to the management of airspace could be required as a result of the additional airport capacityoutlined in the 2003 White Paper? Are the White Paper’s projections for increased passenger demand stillaccurate? Are all the measures to provide for increased passenger demand likely to be implemented?

Additional airport capacity would mean a necessary associated increase in airspace capacity in order tohandle the increase in traYc into/out of the airports at the same time. Depending on whether this is to anincreased capacity at an existing airport (eg by additional runways), to an airport that is currently underusedor to an all-new airport, the need for additional feeder and departure routes emerges. It also means that therequired dimensions of the supporting airspace need to be increased. With the London Terminal Airspace(TMA) currently already on the edge of its capacity limits, and given its close proximity to the airspace ofthe Netherlands, Belgium and France, this could not be accommodated without more advanced interfaces tothe ATC facilities supporting those airspaces or, preferably, a common, integrated airspace design betweenLondon TMA and adjacent airspace. The application of advanced navigation capabilities will be a must asthis will enable a better airspace design to respond to safety, capacity, environmental and flight eYciencychallenges. This would require a closer integration of the UK ATC system with the adjacent systems. Achange of how the airspace is managed would therefore, for the London area, seem to make sense.

2. Can safety be maintained as airspace is increasingly utilised? Is there a suitable interface between militaryand civilian arrangements for air traYc control?

The interface between civil and military control is, in the case of the UK and for those areas in the UKthat are positively controlled (all aircraft receive mandatory ATC, irrespective of the flight rules under whichthey operate), already optimal. The requirement to handle more traYc into the London area with the sameor better safety levels will, however, require a fresh look at the sustainability of the amount of uncontrolledairspace just Northeast of London below FL 245 (% 24.500 ft altitude). Any airspace changes of this sizewill be supported by a Safety case whereby the demonstration of maintenance or improvement of safetylevels will be required. UK has long experience in implementing Safety Management System in Air TraYcManagement (eg UK NATS is actively engaged in EUROCONTROL Safety Team since its inception 10years ago). Therefore it is expected that a robust safety case will be put forward covering the completelifecycle of the airspace change, prior, during and past implementation. In addition, the implementation ofadvanced navigation applications and capabilities will play a major role in maintaining and enhancing thecurrent safety levels.

3. Is the current approach to planning and regulating the use of UK airspace adequate? Would an AirspaceMaster Plan covering the period of the White Paper be beneficial? Could a piecemeal approach to individualdevelopments necessitate additional redesigns subsequently?

Whereas the current approach to the planning and regulation of the UK airspace will certainly beadequate, it should be understood that the interface with the adjacent, non-UK airspace will becomeincreasingly important. Currently there are no formal planning and/or regulatory mechanisms to cover that,except those as contained in the European Commissions (EC) Single European Sky (SES) regulations andthose contained in the European airspace planning process as executed by EUROCONTROL. The UKobserver status in the development of the Functional Airspace Block Europe Central (FAB EC), coveringBenelux, France, Switzerland and Germany, does not seem to be a suYcient measure to overcome this. AnAirspace Master Plan covering the period of the White Paper and drafted in consultation with andcommitment of the FAB EC States seems a bare minimum. A European network approach to the airspacedesign will for sure overcome the inadequacies of a piecemeal approach and will avoid the necessity toredesign airspace at a later stage. The European airspace planning process as executed byEUROCONTROL is well placed to support such an approach.

4. How are the eVects and aircraft noise and emissions taken into account when changes are made to the useof airspace? Who should be consulted about such changes? How should the balance between conflicting interestsbe struck?

Although higher traYc loads in and out of airports will undoubtedly increase noise and emission levels,a number of steps can be taken to mitigate against, or at least reduce, the negative impact, such as:

— Steeper, improved and unrestricted climb-out procedures;

— Steeper, improved continuous descent profiles into airports;

— Holdings (if necessary) at higher, more optimum altitudes; and

— Financial incentives for encouraging the use of more environmental-friendly aircraft; disincentivesfor less environmental-friendly aircraft.

Who should be consulted and how a proper balance should be achieved between conflicting interests isnot an Air TraYc Management (ATM) issue but rather one of political consideration.

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5. How does the management of airspace in the rest of Europe aVect flights into the UK? Is there an opportunityto integrate our plans for changes to airspace management more eVectively with those of other Europeancountries?

The design, planning and management of airspace in Europe needs to be moving towards an increasedlevel of (international) integration. This is particularly pressing for the very dense airspace of NorthwestEurope (area Manchester-London-Paris-Zurich-Frankfurt-Amsterdam-Manchester) where arrival anddeparture procedures are by nature cross-border and where rigid State borders and issues of nationalsovereignty are no longer conducive to facilitating optimum flight profiles. It is for that very reason that theEC has insisted on the creation of FABs, although the EC view appears to be even more ambitious thanwhat is currently achieved by eg FAB EC (see pt 3 above). An integrated design, planning and managementof airspace for Northwest Europe is considered a firm prerequisite for future cost-eYcient andenvironmental-friendly aviation growth.

6. What opportunities are there to apply new techniques and technologies to reduce wasteful flying on indirectroutes and excessive “stacking” while planes wait to land? How can the potential of any such opportunities bestbe realised? Could environmental benefits be gained as a result of such improvements?

The application of “User Preferred Trajectories” (or direct routes) is clearly a requirement by the airlineindustry and it has the potential to bring tangible benefits for the en-route part of the flight. Such initiativesare emerging in the European airspace, including the United Kingdom Positive eVects can be also expectedfrom a better metering long-range sequencing of arriving traYc into TMAs and airports, with early speedadaptations to avoid “stacking”. Although current avionic capabilities on board modern aircraft certainlyhave the capability to adjust speed to a certain extent to meet the so-called “Required Time of Arrival”(RTA) over a geographical point, the scope for this should also not be over-estimated, as the speed rangeof an aircraft at cruising altitude is very limited (around 20 kts (nautical miles per hour) either way). A speedreduction of 20 kts at cruising altitude for a total flight-time of 75 minutes results in no more than 2 minutesdelay. The ability to reduce or increase speed of an aircraft significantly increases at lower altitudes; yet thisis highly undesirable as the fuel and emission penalty would be disproportional. The solution wouldtherefore be an increased and improved linkage between the planning of a flight’s departure slot (eg atFrankfurt) and its arrival slot (eg at Heathrow), with improved sequencing tools in the ATC systems inthe TMA.

7. In relation to the redesign of UK airspace, is the allocation of the roles and responsibilities of each of theinterested parties—Department for Transport, the CAA, airport operators, NATS, etc—appropriate andclearly understood? Are the structures of the parties appropriate for undertaking the roles that they should play?

The roles and responsibilities with respect to the redesign of the UK airspace are clear and wellunderstood. However, as stated above (see pt 5 above), airspace planning, design and management and thepre-requisite processes can currently hardly be considered as a national, sovereign responsibility anymoreand really needs to be addressed in a pan-European context, perhaps facilitated by a suitable entity such asEUROCONTROL, with full participation and commitment of national bodies.

8. Do airspace management considerations delay the planning processes in relation to airport developmentproposals? How will airspace management considerations be taken into account by the proposed newInfrastructure Planning Commission and the relevant National Policy Statements on airport planning?

Until now, airspace design and ASM have not impeded airport developments, as the latter appears to bemore political sensitive and time consuming. However, it is certainly true that with dynamic and ambitiousairport development plans in place, airspace design and ASM could, due to its cross-border dimension,become a more constraining factor than today.

9. What could be the implications for smaller airfields, recreational flying and helicopters of changes toairspace management to enable safe and eYcient increases in capacity at the UK’s major airports? How shouldan appropriate balance between conflicting priorities be determined?

Higher demand for access into and out of large(r) airports certainly mean the requirement for moreenlarged areas of fully controlled airspace. This is certainly true for the airspace below 24.500 ft altitude tothe Northeast of London (see pt 2 above). However, by adopting the requirement for enhanced departureand arrival profiles (see pt 4 above), the impact on the lower airspace (certainly below 10.000 ft altitude) inthe proximity of these large(r) airports could be minimized for the operation of low-level recreational aircraftand helicopter traYc.

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10. Will it be possible to recruit and train staV in order that airspace changes can be implemented in parallelwith additional airport capacity?

Whereas it would certainly be possible to recruit and train such staV, another possibility is to make useof pan-European expertise which already exists.

11. Who should fund airspace changes? Is there likely to be enough funding to undertake the redesign requiredto bring about the necessary additional airspace capacity?

Airspace design is considered to be an element of ATM, together with ATC provision and Air TraYc FlowManagement ATFM, which cost is or can be fully covered through the mechanism of charging the airspaceusers for the ATM services through the EUROCONTROL Central Route Charges OYce (CRCO) inBrussels.

Should you have any questions or comments on the responses above please do not hesitate to contact me.I am also available, if requested, to support with my presence the debates you may have during your inquiry.

Please accept Sir, the assurances of my highest consideration.

February 2009

Memorandum from British Microlight Aircraft Association (AIR 40)

1. What changes to the management of airspace could be required as a result of the additional airport capacityoutlined in the 2003 White Paper? Are the White Paper’s projections for increased passenger demand stillaccurate? Are all the measures to provide for increased passenger demand likely to be implemented?

1.1 No comment.

2. Can safety be maintained as airspace is increasingly utilised? Is there a suitable interface between militaryand civilian arrangements for air traYc control?

2.1 No comment.

3. Is the current approach to planning and regulating the use of UK airspace adequate? Would an AirspaceMaster Plan covering the period of the White Paper be beneficial? Could a piecemeal approach to individualdevelopments necessitate additional redesigns subsequently?

3.1 With the concept of the Single European Sky and the desire of Government to increase air traYc tofacilitate commercial interests it is unthinkable that the basic layout of the UK airspace plan would not beunder consideration. If there has been no coordinated study to date it should form the backbone of anyproposed airspace development. Adding airspace as-and-when will result in conflict of interest and ahaphazard outcome.

4. How are the eVects and aircraft noise and emissions taken into account when changes are made to the useof airspace? Who should be consulted about such changes? How should the balance between conflicting interestsbe struck?

4.1 No comment.

5. How does the management of airspace in the rest of Europe aVect flights into the UK? Is there an opportunityto integrate our plans for changes to airspace management more eVectively with those of other Europeancountries?

5.1 See our comment at 3.1 above. The UK airspace system and traYc flow must be integrated with therest of Europe to achieve standardisation which will result in a higher level of safety, and cooperation whichwill achieve a higher level of eYciency.

6. What opportunities are there to apply new techniques and technologies to reduce wasteful flying on indirectroutes and excessive “stacking” while planes wait to land? How can the potential of any such opportunities bestbe realised? Could environmental benefits be gained as a result of such improvements?

6.1 No comment.

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7. In relation to the redesign of UK airspace, is the allocation of the roles and responsibilities of each of theinterested parties—Department for Transport, the CAA, airport operators, NATS, etc—appropriate andclearly understood? Are the structures of the parties appropriate for undertaking the roles that they should play?

7.1 The role of non commercial General Aviation should be considered when airspace is designed. Civilaviation is not all commercial aviation. There are many more private aircraft being flown by many moreprivate pilots than there are commercial aircraft. Whilst the scale of commercial operations is understood,and important, there must always be a consideration for non commercial activities which fly as a right andnot just as a result of a charitable gesture from commercial operators.

8. Do airspace management considerations delay the planning processes in relation to airport developmentproposals? How will airspace management considerations be taken into account by the proposed newInfrastructure Planning Commission and the relevant National Policy Statements on airport planning?

8.1 No comment.

9. What could be the implications for smaller airfields, recreational flying and helicopters of changes toairspace management to enable safe and eYcient increases in capacity at the UK’s major airports? How shouldan appropriate balance between conflicting priorities be determined?

9.1.1 Referring to the answer given in 7.1 above it must be remembered that the number of noncommercial aircraft is greater than commercial and these are flown by a great deal more people than flycommercial operations. There has been a frantic desire among commercial operators to expand theircapacities to have a larger share of a, prior to now, growing market. Although a commercial airport on thedoorstep of every citizen of the UK may be the dream of some it is an unsustainable and unrealistic dream.There is a limit to the number of passenger seats available in the air at any one time and at some pointexpansion must cease as capacity is reached. In my opinion this point came during, if not before, 2008.Continuing to attempt to expand commercial air transport for the wealth of a few against the tide ofeconomic downturn and supposed attempts to reduce the aVect of aviation on the environment is folly.Planning airspace should now concentrate on eYcient use of that available by using shorter track miles,better coordination of flights to avoid stacking and requiring aircraft to be flown at high capacities ratherthan half full to maintain a timetable. Recreational aviation has enough space now but commercial activityexpansion for the sake of financial gain cannot be allowed to reduce that capacity.

10. Will it be possible to recruit and train staV in order that airspace changes can be implemented in parallelwith additional airport capacity?

10.1.1 No comment.

11. Who should fund airspace changes? Is there likely to be enough funding to undertake the redesign requiredto bring about the necessary additional airspace capacity?

11.1 Airspace changes should always be funded by those who benefit. This will usually be the commercialcarriers and users of the airports that require the airspace and the airspace controllers, usually NATS. Theseairspace changes which benefit the user must be funded by the user. They can always pass the costs on tothe customer in the form of increased fare and freight charges.

February 2009

Memorandum from the General Aviation Safety Council (GASCo) (AIR 41)

In response to your request for a submission we would like to make it clear that GASCo’s objectives areto improve safety in general aviation in the UK and our response only covers this area. You ask about theeVect on smaller airfields, recreational flying and changes to airspace management to enable safe andeYcient increases in capacity at the UK’s major airports. Very briefly:

— Expansion of regulated airspace would generally lead to a narrowing of corridors freely availablefor general aviation use and to the worsening of “choke points”. This increases the risk of mid-aircollision and of airspace infringements. The problem is worst around large conurbations.

— Expansion of existing airports or development of new ones should only be permitted when thereare no other airports within reasonable reach.

— Proposals to set up “Mandatory Transponder Zones” around regulated airspace are impossible foraircraft ranging from vintage types such as the Tiger Moth to microlights and gliders.

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— Furthermore any expansion of such airspace could result in forcing general aviation aircraft to flyround such areas taking them over built up areas, high ground, over water or close to wind farms.This is highly undesirable.

— Under some circumstances general aviation aircraft can be cleared by air traYc control to routethrough regulated airspace but this is dependent upon controller workload. Any proposedexpansion must ensure staYng levels able to handle general aviation traYc.

— The Inquiry should bear in mind that most airline pilots have started their flying careers and /orgained experience through general aviation flying and the recent successful Hudson River ditchingmay in part owe it’s outcome to the pilots gliding background.

We hope this is of help to the Inquiry.

February 2009

Memorandum from Airbus UK (AIR 42)

1. Introduction

1.1 Airbus welcomes this opportunity to contribute its views as part of the Transport Select Committee’sinquiry into “The use of airspace”. Airbus in the UK is a subsidiary of Airbus SAS and owned by EADSNV, a global leader in aerospace, defence and related sectors. Airbus is a global company with major designand manufacturing facilities in France, Germany, the UK and Spain as well as subsidiaries in the US, Chinaand Japan.

1.2 Over the past three decades Airbus has developed into a European success story, securing marketparity with Boeing in a market previously dominated by US companies. Airbus delivered 483 jetliners in2008, surpassing its previous year’s total by 30, and achieving the highest ever on-time rate and quality level.As of 31 December 2008, Airbus has delivered a total of 5,500 aircraft and has total sales of more than 9,200.

1.3 Airbus’ strong sales and continuing growth mean that we have a significant interest in preventing thesaturation of the skies above the UK. A clear plan to improve the current Air TraYc Management (ATM)system will allow airline capacity to meet continued growth in passenger and cargo demand. Airbus’ missionis to meet the needs of airlines and operators by producing the most modern and comprehensive aircraftfamily on the market, complemented by the highest standard of product support.

1.4 This submission sets out Airbus’ views on the Use of Airspace and provides responses to some of thespecific questions posed by the Committee. The submission primarily addresses the technological advancesin ATM, and the environmental, safety, and air traYc benefits that these will bring.

2. Airbus and the Environment

2.1 Airbus places its environmental responsibilities at the forefront of its considerations when planningfuture developments. As part of our commitment to reducing the environmental impact of ourmanufacturing and operating aircraft Airbus is committed to a number of initiatives.

2.2 Airbus invests up to ƒ500 million per year so that all new Airbus aircraft types entering the marketfrom 2020 onwards will be designed to produce 50% less CO2, 80% less NOx and 50% less than comparableaircraft designed and operated in 2000.

2.3 Specific ambitious targets have been set to reduce the environmental impact of Airbus manufacturingactivities. With 2006 as a baseline, the objectives for 2020 are to reduce:

— Energy consumption by 30%.

— CO2 emissions by 50%.

— Water consumption by 50%.

— Water discharge by 80%.

— Waste production by 50%.

2.4 In January 2007, Airbus became the first aerospace company in the world to receive the internationalISO 14001 certification for environmental management systems covering its 16 manufacturing sites andhead oYce in Toulouse, as well as all products throughout their lifecycle.

2.5 Airbus is involved in the Atlantic Interoperability Initiative to Reduce Emissions (AIRE), ASPIRE(Airservices Australia and the Asia and South Pacific Initiative to Reduce Emissions) and INSPIRE (IndianOcean Initiative to Reduce Emissions Group). AIRE’s role is to make it possible to speed up the applicationof existing technologies and new operational procedures which will have a direct impact in the short andmedium term on greenhouse gas emissions. AIRE will be based on “gate to gate” test campaigns andexperiments, which will assess the new measures’ environmental benefits and their operational and technicalfeasibility.

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3. Airbus and Air Traffic Management

3.1 Airbus has no significant business interests in ATM technology itself. However, allowing thesustainable growth of air transport is clearly relevant for the aircraft manufacturing industry.

3.2 Boeing and Airbus signed an agreement to work together at the third Aviation and EnvironmentalSummit in Geneva in April 2008, to ensure global inter-operability in Air TraYc Management as part of aneVort to help reduce the impact of aviation on the environment. This joint initiative to help the aviationsector and governments choose the most direct path to a modernised air traYc management system is partof a three-pronged approach to help improve the environmental performance of aviation.

3.3 Airbus is using its expertise as an industrial architect in the Single European Sky ATM Research(SESAR) programme. Boeing is using its expertise in the equivalent programme in the USA, the NextGeneration Air Transportation System (NextGen) programme. NextGen and SESAR work in co-ordination with each other, sharing developments and advances in order to reach the common goal—aneYcient integrated global ATM network.

3.4 The SESAR programme is a European public-private partnership involving 29 partners working todevelop a modernised ATM for Europe. In order to support the growth of air traYc whilst reducing theenvironmental impact of each flight by 2020, SESAR’s targets are:

— SuYcient planning for a threefold increase in airspace capacity in Europe.

— Air traYc safety improved by a factor of 10.

— The environmental impact of each flight reduced by 10%.

— The cost of ATM halved.

3.5 The SESAR programme has now completed its Definition Phase producing an ATM Master Plan.The SESAR Joint Undertaking (SJU), involving the EC, Eurocontrol, and 15 industry members has beenset up in order to implement the Development Phase of SESAR. Specific aims of the SJU are to save, onaverage, per flight:

— 8 to 14 minutes.

— 300 to 500 kg of fuel.

— 945 to 1575 kg of CO2.

3.6 Airbus, with support from other divisions of EADS, including EADS Defense and Security, andEADS Astrium, is responsible for the industrial support function of SJU. This will ensure the technicalcoherence of the SJU work programme executed by the members. The Industrial Support function involvesproviding expertise in industrial methods and tools to all participants to ensure the proper integration of allprogramme results into the new global ATM system.

3.7 Airbus will also be a major contributor to the operational work packages supporting the OperationalRequirements and Interoperability Standards development activities within SESAR. Airbus leads SESAR’saircraft system work package. The Research and Development activities focus on the evolution of ATMcapabilities of the aircraft platform.

Responses to Specific Questions

4 Q2. Can safety be maintained as airspace is increasingly utilised? Is there a suitable interface betweenmilitary and civilian arrangements for air traYc control?

4.1 In the frame of an integrated performance-based approach, safety can be maintained as airspace isincreasingly utilised. One of the major stated goals of SESAR is a threefold increase in airspace by 2020whilst increasing safety by a factor of ten. The main constraint to airspace capacity is controller workload.To address this issue SESAR has indentified several areas which can be improved. SESAR targetsimprovements that will lead to a significant reduction in the need for tactical intervention by an air traYccontroller by:

— Reducing the number of potential conflicts of flightpaths using a range of methods.

— Possibly redistributing some tactical interventions to the pilots. This will be enabled by the futureCommunications, Navigation and Surveillance (CNS) systems and ATM applications installed onthe aircraft (eg ASAS (see Q.6 below).

It is part of the SJU mission to develop those tools and verify that the capacity and safety balance is met.

4.2 The SESAR project believes that optimising military and civilian ATM activities is essential. TheSESAR Definition Phase involved military organisations in the establishment of the new ATM concept. TheSJU has established a dedicated plan for civil-military coordination to ensure continued integration and co-operation.

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Ev 232 Transport Committee: Evidence

5 Q3. Is the current approach to planning and regulating the use of UK airspace adequate? Would an AirspaceMaster Plan covering the period of the White Paper be beneficial? Could a piecemeal approach to individualdevelopments necessitate additional redesigns subsequently?

5.1 Airspace optimisation should go hand in hand with the renewal of the ATM system to overcomecurrent fragmentation. SESAR final targets can only be reached when the institutional and regulatorymeasures are deployed. Anything less than a planned long-term integration risks a continuation of thecurrent fragmentation and associated ineYciencies. In this respect, Airbus fully supports theimplementation of the four Single European Sky (SES) II regulations, in particular:

— “The SESAR (Single European Sky ATM Research) programme should help in the developmentof future technology.”

5.2 Developments in the ATM system should be taken with a clear focus on global interoperability. Toachieve this, these developments should proceed as part of a co-ordinated evolution, designed from theoutset with a view to achieving an ultimate goal of integration. Any single development should have theprimary goal of improving a higher-level, unified ATM network / system.

6 Q4. How are the eVects and aircraft noise and emissions taken into account when changes are made to theuse of airspace? Who should be consulted about such changes? How should the balance between conflictinginterests be struck?

6.1 The role of ATM is to enable airspace users to fly their preferred trajectory. This trajectory is typicallya trade oV between the economic, network, and environmental concerns, and as such will contribute to thereduction of the fuel consumption to the maximum extent possible in a given context. An eYcient andoptimised ATM system will ensure minimum aircraft waiting time (stacking) near airports and as such willnot only reduce local air and noise pollution but also total flight time and consequently overall flightemissions.

Locally (at airports), the discussion should involve airspace users together with the airport operator andthe surrounding community representatives and groups to find the right balance between eYcient aircraftmovement and noise. Some examples are “Green approaches” such as CDA (see Q.6), and reduction ofholding patterns and taxi time.

7 Q5. How does the management of airspace in the rest of Europe aVect flights into the UK? Is there anopportunity to integrate our plans for changes to airspace management more eVectively with those of otherEuropean countries?

7.1 As discussed previously, since air traYc is a global activity it is important that developments andmanagement of the European ATM systems be planned in a global context.

8 Q6. What opportunities are there to apply new techniques and technologies to reduce wasteful flying onindirect routes and excessive “stacking” while planes wait to land? How can the potential of any suchopportunities best be realised? Could environmental benefits be gained as a result of such improvements?

8.1 Airbus’ key ATM targets compliment Airbus’ activities for SESAR. Airbus’s ATM vision is set outin the following three targets:

— More precise aircraft navigation to give the ability to fly more eYcient routes. More eYcientrouting means that aircraft performance can be optimised during a given flight, resulting in lowerfuel consumption and gaseous emissions.

— More autonomous aircraft to increase flexibility and further reduce risks. More autonomousaircraft will be able to operate more independently of ground infrastructures in lower equippedairspaces and airports, and with increasing situation awareness in dense traYc areas and badweather conditions.

— More communicative aircraft that will have an improved ability to transmit data not only fromindividual aircraft to ground stations, but also inter-aircraft. The more communicative aircraft willalso transmit a larger range of information in order to facilitate the improved ATM system.

8.4 To meet the SESAR and Airbus’ co-ordinated ATM vision Airbus is engaged in trials of variousconcepts and technologies. Airbus operators will be able to take full advantage of new technologies throughthe enhanced Communications, Navigation and Surveillance (CNS) capabilities that will be introducedonboard Airbus aircraft in the coming years. Several of technologies/concepts are set out below, includingsome that are already being used on in-service aircraft:

— Low Required Navigation Performance (RNP). RNP is a standard that defines the accuracy of themeasured location of the aircraft. A low RNP means that the aircraft will fly with high accuracyalong the desired flightpath. A RNP value of 0.1 for example means that an aircraft must fly within

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0.1 nautical miles of the centreline of the flight path, with a 95% probability of that accuracy. Theincreased accuracy of a low RNP means that aircraft, terrain and obstacle separation distance canbe reduced, hence increasing air capacity.

— Continuous Descent Approach / Tailored Arrivals. Continuous Descent Approach involvescalculating the optimal aircraft approach to an airfield. Calculating this approach allows acontinuous steady descent with engines at idle, hence reducing fuel burn, gaseous emissions, andnoise pollution. Airbus A380s have been used in the ASPIRE and INSPIRE programmes testingthis very concept. The trials have been a great success, saving hundreds of tonnes of fuel and carbondioxide emissions. Closer to home, Airbus A330s and A340s have been used as part of AIREtransatlantic trials of similar techniques, which again produced very positive results.

— Airborne Separation Assistance Systems (ASAS). Technologies such as the ADS-B (AutomaticDependent Surveillance—Broadcast) surveillance tool are already being deployed across newaircraft. Currently most surveillance data is sent only between an individual aircraft and theground stations. With ADS-B the aircraft related data is sent to whoever is equipped to receive it,ie other aircraft. This can provide a quicker and more accurate display of traYc information toeach aircraft. It can also be used in areas with low or no radar coverage, significantly increasingthe safety of flying in those areas. Most new Airbus aircraft are fitted with ADS-B capabilities, withthe possibility of an easy upgrade to all older Airbus aircraft. The Airbus ADS-B system has beendesigned to work along with the corresponding ground station systems, such as AURORA (http://www.adacel.com/press/whitepapers/Aurora White Paper 07.pdf). Trials of the technology arebeing conducted within Europe as part of the Eurocontrol Cascade programme. (http://www.eurocontrol.int/cascade/public/subsite homepage/homepage.html). The first operationalapprovals for ADS-B in a non-radar environment are expected by late 2009.

— On Board Airport Navigation System (OANS). An OANS system is a highly useful tool for thecrew of an aircraft. It includes, among other features, an airport moving map with aircraft overlay.This provides the crew with improved situational awareness on the airport surface, and so will cutdown on time spent on runways and taxiways especially in poor visibility conditions. The OANSalso gives prompts for the next course of action, ie braking selection or Air TraYc Control (ATC)path. OANS is already a feature of the A380 and has been in service since October 2007. Airbusis continuously working on ways to utilise fully the potential of OANS. OANS has been designedin such a way that upgrades can easily be added to the system as and when the new capabilitiesachieve certification.

— Brake to Vacate (BTV). BTV is a system that allows pilots to select the appropriate runway exitwhile the aircraft is making its landing approach. When the aircraft touches down the systemregulates deceleration, enabling the aircraft to reach any chosen exit at the correct speed under theoptimum conditions—no matter what the weather and visibility. Ensuring aircraft are at thecorrect speed at the runway exit enables less time to be spent on the runway, thereby making moreeYcient use of the runway and allowing for higher levels of traYc. BTV will go into service on thefirst Air France A380, due to be delivered in early 2009.

— On Board Information System. Onboard Information Systems (OIS) entered into service with theAirbus A380 aircraft. Among other information, the OIS provides the crew with performancecalculations, electronic navigation charts and maps, and electronic operational documentation forthe aircraft, such as flight crew operating manuals. Improving the flexibility, clarity andinteractivity of the OIS will allow crew to use the new technologies with ease, as well as reducingthe time spent selecting existing functions.

8.4 Developments in CNS technologies and techniques will result in greater flightpath predictability forless conflicting / more direct routings. This will reduce stacking and in turn result in reduced fuel burn,gaseous emissions, and noise pollution.

February 2009

Memorandum from the British Parachute Association (BPA) (AIR 43)

INCORPORATION OF SPORT PARACHUTING ACTIVITY WITHIN UK CONTROLLEDAIRSPACE.

Background

Sport Parachuting in the UK is a large, well organised sector of the recreational aviation spectrum. TheBritish Parachute Association (BPA) has been in existence for nearly 50 years and its member clubs nowperform in the region of 250,000 parachute descents every year which includes an average of over 30,000participants each year.

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Ev 234 Transport Committee: Evidence

The UK is a particularly busy parachuting nation. It is the most active of the European nations. This isillustrated by the fact that, apart from France and Germany (which are also very active), the UK performsmore jumps annually than all the rest of the EU nations put together. It is now very strong in internationalcompetition and holds current world championships in several parachuting events.

The organisational structure of parachuting has changed considerably over the past few decades. Thirtyyears ago there were over forty parachute clubs in the UK. There are currently only 22, though these fewernumber of clubs perform much more parachuting than previously. The main reason for the decline in clubnumbers is the diYculty which is now encountered in obtaining planning permission for locations at whichto conduct parachuting. Very few new sites get planning permission. This means that existing sites must beregarded as immovable and when the locations come into conflict with the developing resource requirementsof other agencies (eg NATS requirements for controlled airspace) then every eVort must be made toincorporate parachuting activity within those developments.

Regulatory Structure

Sport parachuting is regulated in the UK by the BPA under the terms of an Approval issued by the CAA.The BPA therefore conducts the day to day regulation of parachuting but this process is overseen andaudited by the CAA. Although it is possible, under CAA provisions, for a parachuting operation to be setup independently of the BPA, it would prove to be a diYcult process. For this reason there are currently noindependent organisations, so the BPA eVectively controls all civilian and military sport parachuting.

Several BPA clubs currently operate within controlled airspace. These operations are usually conductedunder the terms of a letter of agreement between a specific club and the relevant Air TraYc Service Unit(ATSU). The agreement will detail the precise way in which parachute operations will be conducted in thatparticular sector of controlled airspace and the terms under which the ATSU will provide a service to theclub.

Current Situation

The decline in the number of locations at which parachuting can be conducted has resulted in a trendtowards the acquisition of larger and faster climbing aeroplanes in order to cope with the increasing demandfor the activity. This has provided a beneficial environmental spin oV, insofar as the trend has been awayfrom a large number of small piston engined aircraft towards a smaller number of turbine engined aircraft.

In terms of ATC management this is also advantageous. The larger turbine aircraft are faster and servicea set number of parachute jumps with fewer number of flights than their smaller piston engined predecessors.This makes it easier for ATC to incorporate a parachute operation within its routine activity.

The amount of airspace which parachuting activity takes up within the UK is also tiny. Each notified dropzone occupies a circle with a radius of 1.5 nautical miles and a maximum altitude of Flight Level 130. It isnot permitted for parachute descents to take place outside of this area. Although the aircraft performingparachute drops will often fly outside of this area in the course of their ascents and descents, they do notneed to move far from the area and can easily be directed to conform with immediate air traYc controlrequirements.

Future Requirements

It is clear that the need for controlled airspace is increasing and will continue to do so and that this increasewill necessarily be at the expense of the finite area of uncontrolled airspace within the UK. This willinevitably mean that parachuting drop zones will become increasingly located within areas of controlledairspace. It is obvious that parachuting activity close to a major airport would not be desirable and this isreflected by the fact that drop zones do not exist close to them. They do, however, exist in wider areas ofcontrolled airspace and have done so successfully for many years.

Future airspace planning policy should therefore incorporate provision to enable parachuting activity tobe conducted within controlled airspace. There is perhaps a tendency for parachuting to be regarded as anuisance factor within enroute air traYc control systems. This is simply a reflection of the fact thatrecreational aviation generally has come to be regarded as expendable when set against the sacred totem ofcommercial air transport. The only rationale behind this is that commercial air transport is a bigger industry.This does not, however, make it any more worthy and we believe that airspace planning policy should makeprovision for parachuting operations to be catered for within any airspace expansion plans.

The BPA wishes to ensure that it is closely involved with any planning procedures that are likely to aVectits continued activity and would welcome assurances that it will be involved in this way.

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Summary

1. Sport parachuting is well organised and thriving within the UK.

2. Some clubs currently operate successfully within controlled airspace.

3. Parachuting locations are few and planning restrictions make them immovable.

4. The total airspace required by parachuting activity is tiny and manageable.

5. Future airspace planning should therefore incorporate parachuting activity if necessary.

6. Parachuting should not be regarded as expendable in airspace planning but as a rightful user whoserequirements can be managed within an ATC system.

The British Parachute Association appreciates being given the opportunity to make this submission andwill be happy to expand upon any of the brief detail included here. Any request for further information willbe given immediate attention to enable a rapid response.

February 2009

Memorandum from BAA Airports Limited (AIR 44)

1. Introduction

This paper sets out the policy position of BAA Airports Limited (BAA)on the use of UK airspace generally and in relation to the demands placed on it by the forthcomingexpansion of airport capacity as presented in the 2003 Future of Aviation White Paper. BAA has workedcollaboratively with NATS and CAA’s Directorate of Airspace Policy (DAP) on these issues in thepreparation of Heathrow’s Runway 3 and Stansted’s G2 proposals.

BAA has also been involved in the recent AOA submission to the Committee.

2. Response

BAA believes that a consolidated approach to the future strategy for UK Airspace is essential forconsidering the future increase in demand for air traYc capacity in the UK.

In our view it appears likely that the CAA’s DAP is best placed to receive and coordinate views inestablishing and being subsequently accountable for such a strategy.

BAA agrees that the correct approach to developing controlled airspace in the UK is to establish theoperational, safety and environmental case within such an overall strategy and masterplan to ensure thatthe future needs of all airspace users are met and that balance is achieved between their respective interests.

This would mean that controlled airspace is only increased to meet the sustained needs of commercial airtraYc but no more and that other airspace users who require unfettered use of uncontrolled airspace couldbe expected to do all they can to ensure that such controlled airspace that exists is not infringed, standardsof airmanship improved and radio contact maintained where this can be proved by ANSP’s to deliver thedesired safety and capacity benefits.

BAA believes that it will become increasingly diYcult to completely reconcile the interests of allstakeholders in future airspace change proposals made necessary by increased aviation activity. In our viewit is unrealistic to expect any airspace change proposal to pass through unchallenged and therefore we believethat the DfT and DAP have an accountability to stakeholders to establish the weighting put to the variedinterests surfaced by an airspace change and this will greatly assist in building in robustness to proposals.Sponsors of the change and relevant stakeholders should not be delayed unnecessarily in hearing theoutcome of an airspace change proposal.

Where an increase to the extent of controlled airspace is desirable, the costs of the processing of an airspacechange proposal through the regulator and all associated design and public consultations should be met bythe beneficiaries of such an increase, which would be the airspace users.

For the future, BAA is committed to the aims and objectives of the SESAR (Single European SKY ATMResearch) programme in increasing capacity up to three times present levels, halving the cost of en route airtraYc services to airlines, improving safety by a factor of ten and reducing environmental impact per flightby 10%.

Recent initiatives to use airspace more eYciently and collaboratively through civilian/military interactionand the creation of FABs (Functional Airspace Blocks) are to be welcomed and expedited to meet some ofthe SESAR initiatives. Examples of this would be the reduction in miles flown for a given sector because ofmore direct routeing and the reduction in costs as the creation of FABs transcends the need for sovereignairspace, controlled by the most eYcient service providers.

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Ev 236 Transport Committee: Evidence

Other examples of where SESAR might make a diVerence in the UK would be the reduced requirementto hold aircraft awaiting arrival at our most congested airports. There are tools and techniques underdevelopment which could unlock solutions in this area. CDM (Collaborative Decision Making) is anotherexample where the prospect of sharing and communicating data oVers step changes in the eYciency of theaircraft turnaround process reducing delay, improving punctuality and predictability and making best useof costly infrastructure and assets namely runways, aircraft parking stands and aircraft. At a time when theindustry is becoming seriously eVected by global economic instability, measures such as these are essentialrather than desirable.

BAA has just submitted a bid to become a member of the SESAR Joint Undertaking alongside Aeroportsde Paris, Schiphol Airport, Munich Airport, Fraport (Frankfurt) and Unique(Zurich). Our bid has not onlybeen coordinated amongst the members of the SESAR European Airport Consortium (SEAC) to providea focus on the way in which Air TraYc Management issues are developed at airport level but has also beencoordinated with other authorities and agencies such as AENA and Eurocontrol to ensure a truly PanEuropean solution.

All members of the SEAC Consortium will liaise with their respective associations whether they benational, in the case of the UK, the Airport Operators Association or European, ACI (Airports CouncilInternational) Europe to ensure that all airports can be involved and participate in SESAR development.

The work eVort invested in SESAR will produce, in time, an ATM framework which will address thecurrent fragmented state of airspace development and will ensure global interoperability throughinternational agreement with the FAA’s NextGen programme and with ICAO.

Above all it is essential for the UK Aviation sector to become involved in SESAR to make sure theoutcomes of the development and deployment phase enhance the UK’s track record in these areas and notbe driven by outside interests. The SESAR programme funding is made up of 2.1 billion euros of cash andin kind contributions from a wide number of industry stakeholders and, despite the economic downturn,there has never been a time in aviations brief history when innovation is more acutely required.

2008 was a diYcult year for air transport and 2009 is set to be even tougher. However demand in the longerterm is set to rise substantially with traYc surging to 18 million movements in 2030. This is no time to losesight of the long term challenges and goals, because the challenges continue to require decisions andactions today.

January 2009

Memorandum from the European Commission (AIR 45)

IMPACT OF AIRSPACE DESIGN IN OTHER EUROPEAN COUNTRIES

European Commission Views

The House of Commons Transport Committee has asked the Commission to present its views on “Howdoes the management of airspace in the rest of Europe aVect flights into UK? Is there an opportunity tointegrate our plans for changes to airspace management more eVectively with those of other Europeancountries?”

The question above is very relevant, since all route networks and air traYc hubs have an impact on eachother. This happens mostly between neighbouring areas, but in Europe’s congested airspace, there is oftena ripple eVect on areas further oV as well.

All of the core area of Europe is strongly interdependent and this is especially the case for the London-Paris-Amsterdam triangle, where we have both Europe’s densest traYc areas and where some of EU’sbusiest airports are so close to each other that their descent and climb paths interact.

The European Commission has been closely involved in matters of reorganising European airspace andensuring maximal use of this scarce resource in the face of increasing traYc, through its “Single EuropeanSky” (SES) initiative. This initiative first materialised in 2004 with the adoption of four Regulations. Theseare the Framework Regulation (EC 549/2004), the Service Provision Regulation (EC 550/2004), theAirspace Regulation (EC 551/2004) and the Interoperability Regulation (EC 552/2004). In June 2008 theCommission proposed a second package (SES2) of measures to update the abovementioned Regulationsand at the time of writing, these Regulations are being finalised with adoption expected in the 2009.

In particular two aspects of the new Single European Sky 2 regulations aVect airspace planning also inthe UK:

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1. Functional Airspace Blocks

The functional airspace blocks are a concept that was introduced already in 2004 to encourage nationalair navigation service providers to co-operate and organise their airspaces without regard to politicalboundaries, but with a view to the actual traYc streams and the needs of all airspace users. Since progress hasbeen slow, the Single European Sky 2 proposal introduces a firm deadline (2012) for all States to implementfunctional airspace blocks. At the same time in Single European Sky 2 the concept is being widened frompure airspace related co-operation to a wider and more flexible range of ways in which the service providerscan optimise their operations and improve performance.

In addition to the UK-Irish initiative for a functional airspace block, there are other functional airspaceblocks being formed around the UK airspace in the neighbouring countries and since these will lead tochanges in their respective airspaces, there will also be impacts on UK traYc flows. Most notably in the coreareas of Europe, the “FAB EC” initiative is moving towards integrating the service provision of Belgium,France, Germany, Luxembourg, the Netherlands and Switzerland and thus reorganising their airspaces.

On the north side of UK, there exists the “NEFAB” initiative, which includes the five Nordic countries,Estonia and Ireland. This project in turn will impact the traYc flows over the Atlantic and over theNordic area.

It has always been EC view, that the functional airspace blocks should not be created in isolation, but witha European network approach in mind. The blocks can be truly functional, only if they co-operate also witheach other and seek to optimise their airspace planning so that a continuum of airspace is created over thewhole of the European airspace. It is for that reason that the new legislation requires Member States andtheir service providers to form co-operation or integration arrangements also with neighbouring functionalairspace blocks.

2. Network management function

A new concept in the Single European Sky 2 proposal is the Network management function. It aims tointroduce an element of planning on network (European) level and thus to maximise the use of scarceresources, such as airspace, radio frequencies and their like.

The route design part of the Network management function will create a central planning function thataims to draft the en-route part of existing route network in a manner that is based primarily on airspaceusers needs. Studies have shown that today most national route networks are still built with the needs of thenational air traYc service provider and local airlines in mind. Hence traYc today flies an average distanceof 49 kilometres too long on intra-European routes.

Under current planning the other Network management function parts will concentrate on co-ordinationand allocation of radio frequencies and certain codes, which are currently in short supply due to poor co-ordination amongst States. However in the future the European ATM modernisation project SESAR willprobably bring more duties for the Network management function to perform and these may also haveairspace impact.

3. SESAR

SESAR is the technological pillar of the Single European Sky. This public/private partnership has veryambitious objectives to provide additional enhanced safety, capacity, environment and flight eYciency.

Funded by the European Union (700 M ƒ), Eurocontrol (a similar figure) and European industry, it hasthe potential to radically change the management of airspace in Europe. UK national service provider(NATS) is one of the key contributors.

March 2009

Supplementary memorandum from the European Commission (AIR 45A)

During the Transport Committee evidence session on 18 March 2009 concerning the use of airspace, thediscussions about the network management function in the recently adopted Single European Sky IIpackage left one particular question unanswered. I would therefore like to come back to the questions 328to 331 from the evidence session and provide you with some further clarifications.

The air traYc management (ATM) network will allow optimum use of airspace and ensure that airspaceusers can operate preferred trajectories, while allowing maximum access to airspace and air navigationservices. The network management function has been designed to assist aviation stakeholders in this process

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Ev 238 Transport Committee: Evidence

from a European network perspective and to complement the introduction of the performance regulation.It will comprise a range of tasks, exercised by diVerent actors including:

— European Route Network Design: to ensure that local design solutions are consistent withEuropean network eYciency requirements within a multi-modal policy and that all airspace userscan fly optimal trajectories;

— Management of scarce resources: to optimise the use of scarce resources, like frequencies ortransponder codes, through a centralised inventory of these resources, with a view to overcomingsometimes conflicting local solutions;

— TraYc Flow Management, slot coordination and allocation: to allocate slots as a function of the“required time of arrival” to improve the predictability of operations;

— Management of the deployment of SESAR technologies and the procurement of European-wideinfrastructure elements: to ensure consistent and synchronised availability of suitable equipmentand management of information networks, as defined in the ATM-Master Plan.

The modalities for executing the functions will be developed in implementing rules, guaranteeing publicinterest impartiality and ensuring appropriate industry involvement. The development of theseimplementing rules will follow the “Community method” (the standard EU decision-making procedure,embracing the Single Sky Committee, the Industry Consultation Body, the social dialogue Committee43 andEurocontrol44 in an institutional framework with wide stakeholder consultation) that has been instrumentalin establishing Single European Sky rules since 2004.

Member States will therefore not only have the ability to address their particular interests in thedevelopment steps of the implementing rule. They will also have the possibility to address concerns, if theyare not convinced about the content of the implementing rule, in the Single Sky Committee where the EChas to obtain a positive opinion of Member States with qualified majority voting procedure. And finallythere is always the possibility for Member States to use the “safeguard clause” in the framework regulationwhich allows Member States the application of measures to the extent to which these are needed to safeguardessential security or defence policy interests.

The success of the Single European Sky is dependent upon the alignment of all actors towards one singlegoal which is to oVer the most performing air traYc management (ATM) infrastructure to the needs of anevolving aviation industry.

April 2009

Memorandum from The British Gliding Association Ltd (BGA) (AIR 46)

It is understood that the Transport Committee will examine progress in preparing for changes to themanagement of airspace and would particularly welcome responses to the following 11 questions: TheBritish Gliding Association (BGA) wishes to make the following comments. A one-page summary of BGAactivities is at Annex A and a Glossary of Terms is included as Annex B. The latter uses words from theGlossary on the web site of the Technical Commission on Airspace and Navigation Systems (CANS) of theFederation Aeronautique Internationale.

Q1. What changes to the management of airspace could be required as a result of the additional airportcapacity outlined in the 2003 White Paper? Are the White Paper’s projections for increased passenger demandstill accurate? Are all the measures to provide for increased passenger demand likely to be implemented?

A1. For the future management of airspace, the BGA believes that in advance of any proposed changes,all stakeholders should be consulted at the outset of the process. On the passenger numbers and movementsof Commercial Air Transport that were predicted in the 2003 White Paper, these may now be anoverestimate. There is a risk of that over-estimates may lead to unnecessarily restricted airspace measuresbeing proposed.

Q2. Can safety be maintained as airspace is increasingly utilised? Is there a suitable interface between militaryand civilian arrangements for air traYc control?

A2. Our experience is that through co-operation between airspace users, safety can often be maintainedwhile airspace utilisation is increased, avoiding the need to jump to new, and possibly restrictive, solutionsbefore they are required.

43 The Sectoral Social Dialogue Committee on Civil Aviation, established on basis of Commission Decision 98/500/EC of20 May 1998, extended to ATM.

44 The European Community became a member of the Eurocontrol Organisation under Council Decision 11053/2 Aviation 121of 17.7.2002.

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In terms of future airspace management, the BGA is aware of a future Air TraYc Management (ATM)system based on Satellite Navigation rather than radar. This is already in use in Australia and is planned tobe introduced in the rest of Europe and North America in the next decade. It is called Automatic DependentSurveillance—Broadcast (ADS-B) and more detail is given in the Glossary. Aircraft ADS-B equipment hasthe accuracy of Satellite Navigation systems such as the U.S. Global Positioning System (GPS), positionalerrors being of the order of 10 metres. Such positions are broadcast to ATM ground stations for controlpurposes and also to other aircraft for proximity warning (anti-collision) purposes. This is much moreaccurate than any radar-based system. Furthermore, accuracy is uniform over large areas compared to radarwhere accuracy degrades with distance away from the radar head.

However, it appears that there is no coherent plan in the UK for the future replacement of radar-basedATM systems with those based on satellite navigation. The relevant UK Authorities should be asked toformulate one. Some advantages of ADS-B over radar are summarised in Annex C which consists of extractsfrom the U.S. Federal Aviation Administration (FAA) Notice of Proposed Rulemaking (NRPM) 7–15dated October 2007.

On the civil/military interface the BGA has no comment except to note that the incidence of Military-to-Commercial Air Transport Aircraft Proximity (AirProx) reports is significant and greatly in excess of thoseinvolving General Aviation and air sport aircraft (figures, Annex D).

Q3. Is the current approach to planning and regulating the use of UK airspace adequate? Would an AirspaceMaster Plan covering the period of the White Paper be beneficial? Could a piecemeal approach to individualdevelopments necessitate additional redesigns subsequently?

A3. In terms of planning and regulation, the BGA believes that the current approach using CAP 724 and725 procedures backed by regular liaison of all stakeholders with ATM authorities, is satisfactory. First,measures that increase coherence and minimise the resources (from all stakeholders) required by the currentsystem should be considered. The cost/benefit of a future and diVerent Airspace Master Plan should becarefully analysed before proceeding. However, in certain areas diVerent circumstances may apply and couldbe overlooked or inappropriately dealt with an over-rigid master plan. It is therefore important that case-by-case considerations are taken into account.

In terms of future aircraft equipment, the BGA is concerned that there has been a proposal by the CAADirector of Airspace Policy (DAP) to impose radar-based Mode S transponder devices on every aircraftflying anywhere in UK airspace45. For visual flight outside Controlled Airspace (CAS), this was stronglyresisted by UK air sport associations including the BGA. Clearly, electronic identification devices such asMode S radar transponders and future Satellite-based systems are required inside busy Controlled Airspace,for the continued safety of the fare-paying passenger. However, when the whole volume of UK Airspace isconcerned, Commercial Air Transport represents a small number of aircraft compared with the total numberof aircraft currently based in the UK (numbers, annex D).

The current result appears to be that, after a second consultation in 2008, DAP is now concentrating onthe establishment of Transponder Mandatory Zones (TMZs) as an addition to existing CAS. However, it isnoteworthy that the DAP Summary of Responses document Issue 1.1 dated 4 December 2008 ends with thewords “the carriage and operation of Mode S transponders in all UK airspace will continue to beencouraged and the benefits publicised”. For visual flight outside CAS, the BGA believes that this isunnecessary. Furthermore, we question radar-based transponders as the long-term technical solution, inview of the remarks on ADS-B above and in Annex C. We would like to see a plan from the DAP or otherrelevant areas of the CAA for the future transition from radar-based aircraft ATM equipment to that basedon Satellite navigation.

Currently, pilots are taught to practice regular visual scans and adopt the “see and avoid” principle. TheBGA believes that, outside CAS, a universal radar-based electronic identification policy is not onlyunnecessary, but shows a disproportionate approach not only to the 2,500 UK gliders but also to the manythousands of light General Aviation (GA) and air sport aircraft currently able to fly in the UK. These aircraftoperate with little adverse interaction with Commercial Air Transport. It is understood from statistics fromthe UK CAA that the GA and sport aircraft sector in the UK comprises some 96% of aircraft based in theUK. These are tabulated at Annex D in terms of broad aircraft categories and total nearly 26,000 aircraft.

Of these 26,000 aircraft, some 13,000 have little or no electrical generation capability and clearly wouldhave diYculty in eVectively operating any equipment that has high current drain, high weight or largevolume. One advantage of GPS-based systems is low current drain and low weight, and many Light GA andair sport aircraft already carry GPS equipment. In the case of competition gliders it is normal to carry twoGPS-based recording devices and many carry a GPS-based proximity warning (anti-collision) system calledFLARM (“Flight Alarm”, for more details see the Glossary).

However, in areas where electronic identification may be required in the future, it is essential that ADS-B equipment is available that not only has low current drain but is at a low enough cost to be aVorded bythe Light GA and sport aircraft sector. We use the term “Light GA” to describe the lower-cost end of the

45 Proposal to amend the Air Navigation Order for the purpose of improving the Technical Interoperability of all aircraft inUK Airspace. Director of Airspace Policy document P-RIA 1.2 for responses by 29 August 2006

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GA market, excluding aircraft such as business jets and turboprops. A modified version of FLARM witha longer-range ADS-B-compatible broadcast link, might be suitable. The BGA would like to see thedevelopment of such systems. These should be accepted by the ATM authorities for flight in areas where itis deemed that electronic identification is required and the “see and avoid” principle has been positivelyshown to be inadequate for the traYc densities in the area concerned.

Q4. How are the eVects and aircraft noise and emissions taken into account when changes are made to the useof airspace? Who should be consulted about such changes? How should the balance between conflicting interestsbe struck?

A4. The eVects of noise and emissions are taken into account during Airspace Change Proposal (ACP)consultations. We support the current CAA document CAP725 process for taking these factors intoaccount. In the future these procedures will become more important. However, as broad a stakeholdercommunity as possible should be involved. Finally, we should point out that gliding generates very low noiselevels and very few emissions.

Q5. How does the management of airspace in the rest of Europe aVect flights into the UK? Is there anopportunity to integrate our plans for changes to airspace management more eVectively with those of otherEuropean countries?

A5. The BGA understands that the rest of Europe is progressing towards the ADS-B system mentionedabove and recommends harmonisation of UK systems through bodies such as Eurocontrol, EASA andEUROCAE (details in the Glossary) under the SESAR programme (Single European Sky Air TraYcManagement Research, see the Glossary).

The BGA engages with European airspace issues through Europe Air Sports (EAS) which represents allair sport organisations in Europe. At an international level, the BGA is represented at the FederationAeronautique Internationale (FAI) which has its HQ in Lausanne, Switzerland. It should be noted that FAIhas a Commission on Airspace and Navigation Systems (CANS), on which the UK is represented andprovides the Commission secretary.

Q6. What opportunities are there to apply new techniques and technologies to reduce wasteful flying on indirectroutes and excessive stacking while planes wait to land? How can the potential of any such opportunities bestbe realised? Could environmental benefits be gained as a result of such improvements?

A6. ADS-B will enable safe separation distances to be reduced and more versatile tracking to be obtainedcompared to flying direct tracks between fixed radio beacons. This is clearly indicated in the U.S. FAAdocument quoted in Annex D. It is understood that separation distances for Commercial Air Transport arelikely to be substantially reduced when ADS-B is fully operational. A figure of three Nautical Miles has beenmentioned, compared to the current five nautical miles.

However, the BGA does not believe that airliners should be encouraged to fly in otherwise free airspace,but should normally fly in the Controlled Airspace that has been provided for them. The implications toother airspace users of allowing or encouraging airliners to fly “oV airways”, could have serious implicationsto both them and the many other users of this airspace, particularly in the lower levels below, say, 10,000ft.

Q7. In relation to the redesign of UK airspace, is the allocation of the roles and responsibilities of each of theinterested parties Department for Transport, the CAA, airport operators, NATS, etc, appropriate and clearlyunderstood? Are the structures of the parties appropriate for undertaking the roles that they should play?

A7. The BGA believes that the light GA and sport flying sectors should have more representation in theseprocesses, particularly in the early stages of any possible changes. The owners and operators of nearly 26,000UK aircraft in this sector (figures, annex D) should have the opportunity to be represented by their relevantAssociations. The BGA and other air sport and GA bodies include highly qualified aerospace professionalswithin their membership (as was stated in our last submission to your Committee in the late 90s) and wouldlike to have greater involvement in the study and planning for these future generation systems. This hasalready been suggested to the DAP area of the CAA. Such forward planning would be to identify at an earlystage where trade-oVs can be made, in order to benefit particular aviation sectors without disadvantagingothers. As an example, DAP’s proposal that Mode S should be fitted to all aircraft flying in all UK airspaceincluding outside CAS, took the GA and sport aviation movements by surprise, although as we now know,the planning for Mode S ground infrastructure had been in place for many years.

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Q8. Do airspace management considerations delay the planning processes in relation to airport developmentproposals? How will airspace management considerations be taken into account by the proposed newInfrastructure Planning Commission and the relevant National Policy Statements on airport planning?

A8. The BGA is satisfied with the existing CAA airspace change procedures laid down in the CAP724 andCAP 725 documents, if properly applied and with due consideration to all airspace users. It is particularlyimportant that when an increased volume of Controlled or Restricted Airspace is being contemplated, theeVect on all airspace users should be taken into account and not just the few. Particularly, it should berecognised that expansion of CAS in one area can lead to so-called “choke points” in others, into whichother aircraft movements will then be concentrated. Already, in some areas near CAS, other traYc hasalready been squeezed into increasingly smaller airspace volumes, with consequent increase in risk.Examples include near Bristol, the narrow gaps between the Brize and Lyneham areas, between Lynehamand the Salisbury Plain ranges, under Daventry CAS, the periphery of the London Terminal Area,Doncaster Robin Hood airspace, Humberside, and so forth.

Q9. What could be the implications for smaller airfields, recreational flying and helicopters of changes toairspace management to enable safe and eYcient increases in capacity at the UK’s major airports?

A9. The BGA is concerned that smaller airfields and recreational and sport flying generally could beseriously threatened by unnecessarily large increases in controlled airspace.

It is also concerned at the trend not only to allow, but apparently to encourage, airliners to fly outsideControlled Airspace (CAS). It believes that CAS is designed for the protection of the fare-paying passengerand that flight outside it by airliners should be the exception rather then the rule, particularly in loweraltitudes such as below 10,000ft where many thousands of light GA and sport aircraft fly.

Q10. How should an appropriate balance between conflicting priorities be determined? Will it be possible torecruit and train staV in order that airspace changes can be implemented in parallel with additional airportcapacity?

A10. The BGA believes that a rigorous risk analysis should always take place before any increase inControlled Airspace is agreed. This should be based on facts rather than surmise, taking into account betterutilisation of existing CAS and an assessment of risk, particularly to the fare-paying passenger. The numberof actual Commercial Air Transport (CAT) movements at a given airport and area should be taken intoaccount when a new volume of Controlled Airspace is being considered. In the case of low densities of CAT,consideration should be given to smaller CAS volumes and/or time scheduling of the application of CAS inaccordance with the actual presence of CAT aircraft.

In terms of AirProx reports, the BGA notes that many are assessed as “no risk” and are essentially“sighting reports”; these should be not be used in risk assessments when new airspace is being considered.However, the low-power low-cost ADS-B equipment mentioned above will help light GA and some air sportaircraft to have continuing access to lower-densities of CAS. As stated above, the existing CAA procedureslaid down in CAP724 and CAP 725 documents are considered satisfactory, if properly applied and with dueconsideration to all airspace users.

Q11. Who should fund airspace changes? Is there likely to be enough funding to undertake the redesign requiredto bring about the necessary additional airspace capacity?

A11. The BGA believes that those who directly benefit from and use CAS should fund airspace changes.Aircraft such as gliders flying outside controlled airspace, should not be subject to extra costs due to futurechanges in airspace or avionics.

March 2009

Annex A

SUMMARY OF ACTIVITIES OF THE BRITISH GLIDING ASSOCIATION

The British Gliding Association (BGA) is a member’s organisation that has for 70 years successfullyprovided the safe, self regulated framework for the sport. It has also taken responsibility for managing theregulation of gliding in the UK under the oversight of the CAA.

The BGA is made up of 90 not-for-profit clubs run by volunteers with some 9000 regular participants and30,000 occasional participants operating some 2,300 gliders along with some 150 self-launching gliders(using a small engine), static winches for launching by cable, and towing aircraft. In addition to instructionalflying primarily in the area of each gliding site, when the weather conditions are suitable, flights over longdistances are common. In these cases, planned flights, including competitive races, are made around turningpoints with the aim of returning to base. This fundamental element of the sport requires participants toutilise thermal up-currents under cumulus clouds, rising air from atmospheric waves in the lee of hills andmountains, and ridge lift where air rises over steep ground features.

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Promotion of youth participation in the sport is a priority for the BGA, and it works closely with SportsCouncils and other agencies to ensure the maximum engagement with all communities.

With progress in structural and aerodynamic technologies, the modern high-performance glider is asophisticated aircraft capable of flying many hundreds of miles using the thermal and wave energy alreadymentioned. Maximum glide ratios have increased steadily over the years. 45:1 is typical of a 15 metrecompetition glider and larger gliders approach 60:1. By comparison, a hang glider has a glide ratio of 10 to15:1. This ratio is of forward speed to sinking speed, and at 50:1 a glider starting at 5000 feet overNorthampton could glide to Evesham (in still air conditions) without any thermal or wave lift.

The longest straight glider flight in the UK was from Lasham in Hampshire to Portmoak, north ofEdinburgh, during a national championship. The longest out-and-return flight was from Lasham toDurham and return, and several flights with multiple turning points of over 1000km (620 statute miles) havebeen flown. These flights can take up to 10 hours to complete.

Between May and September each year, some 500 entries are accepted in BGA-organised competitionswith many hundreds more taking part in club-organised events and leagues. Tasks are scored for speedaround a diVerent course each day which varies with wind and the forecast thermal or wave lift. For thehigher performing competition classes, average speeds round the set course are frequently in excess of 100kilometres per hour (62mph) and courses can be up to 500 km in length (311 statute miles), avoidingControlled Airspace by suitable placing of Turning Points. In thermal lift the height band most frequentlyused is between about 2000 and 6000 feet above ground, but in wave lift, flight to 20,000 ft and above isnot unusual. As mentioned in the main text, competition gliders all carry GPS equipment and GPS-basedrecording devices are used for scoring. The GPS information is also used for flight instruments and fornavigation, and almost all gliders have their GPS position and any nearby controlled airspace presented ona moving-map display in the cockpit.

Similar to sailing dinghies, gliders do not generate electrical power. They rely on batteries to power radiosand navigational instruments.

Gliders range in value. The older wood, metal and fabric covered types commonly used by young people,low income participants and for training because of their low capital and running costs, can be purchasedfor as little as £3,000. A top of the range composite-structure competition glider is at the other extreme wherea syndicate could pay more than £100,000. In this respect the sport is again similar to sailing.

At an international level, British glider pilots regularly bring back Gold medals, and Gliding Team GBis one of the most successful in the world.

A final and important point is that, because a glider pilot needs to be constantly searching the sky aheadfor the next source of “lift”, visual lookout and scan is an integral part of gliding. The “see and avoid”principle is highly eVective in this sector of aviation and the unwanted imposition of other electronic devicesin the cockpit could even detract from it.

Annex B

GLOSSARY OF TERMS

This material is taken from the Glossary of the Federation Aeronautique Internationale’s TechnicalCommission on Airspace and Navigation Systems (CANS):http://www.fai.org/system/files/cans glossary 2009 1 6.pdf

ADS-B—Automatic Dependent Surveillance—Broadcast. The ADS-B system uses Global NavigationSatellite System (GNSS) position data and a relatively simple broadcast communications link. It has beensaid that the ADS-B system is the future for worldwide Air TraYc Management (ATM) and for proximitywarning between aircraft. Programmes implementing ADS-B include CASCADE and SESAR in Europeand NextGen in the USA (see elsewhere in this Glossary). The initials ADS-B originate from the following:it is Automatic, in that it is always live and requires no operator action. Dependent, in that it depends on aGNSS system such as GPS for position data. Surveillance, in that it provides this 3D position data to groundcontrollers and other aircraft. Broadcast, in that it broadcasts data on pre-set radio frequencies to anyaircraft or ground station equipped with ADS-B that is listening. Unlike radar, ADS-B accuracy does notdiminish with range, atmospheric conditions or target altitude and has the same accuracy as GNSS. ADS-B aircraft equipment takes GNSS position data and combines that data with other aircraft information, suchas pressure altitude, airspeed and flight/aircraft identification. This information is then broadcast to otherADS-B-equipped aircraft for proximity warning (anti-collision) purposes. It is broadcast also to ADS-Bground stations for identification, surveillance and Air TraYc Control purposes. It will also work on theground, for instance in monitoring airfield movements and the choice of the correct runway for takeoV inconditions of poor visibility. ADS-B with an appropriate network of ground stations also works in remoteareas or in mountainous terrain where there is either no radar coverage, or where radar coverage is restrictedby obstacles in the line-of-sight. An ADS-B ground station consists of antennas and other equipment toreceive and request aircraft data and either land-lines or microwave links to communicate with Air TraYcControl Centres. An ADS-B ground station is much simpler and less expensive than a surveillance radarstation. As ADS-B becomes operational, the large surveillance radars presently used for civil air traYccontrol, can be phased out in favour of a network of ADS-B ground stations.

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ADS-B in North America. In the USA, the FAA awarded a contract on 30 August 2007 to a consortiumled by ITT Corporation to provide ADS-B surveillance uplink (ground-to-air) and downlink (air-to-ground)services, Automatic Dependent Surveillance Re-broadcast (ADS-R), TraYc Information Services—Broadcast (TIS-B) and Flight Information Services—Broadcast (FIS-B). Ground stations in Florida werecompleted in September 2008 and other areas in North America follow including Canada and the Gulf ofMexico. Under FAA NPRM 7–15 dated 1 October 2007, infrastructure for ADS-B Out, including broadcastservices and 548 ground stations, is to be available by the end of Fiscal Year 2013. The FAA compliancedate for aircraft to be fitted with ADS-B is 2020, and some aircraft (such as those of the freight carrier UPS)are fitted now. ADS-B Out will use the 1090 MHz Extended Squitter (1090ES) or the 978 MHz UniversalAccess Transceiver (UAT) broadcast links. UAT will also be used to uplink Flight Information Service (FIS)information to aircraft.

EASA—European Aviation Safety Agency, the EU regulatory agency for aviation, headquartered inCologne.

EUROCAE—European Organisation for Civil Aviation Equipment. The organisation for certifyingaviation equipment in Europe. It is a non-profit organisation formed from manufacturers of aircraft,airborne equipment, Air TraYc Management (ATM) systems and ground equipment, Service Providers,National and International Aviation Authorities and Users (Airlines, Airports, operators) from Europe andelsewhere. EUROCAE develops performance specifications and other documents that are referenced as ameans of compliance to European Technical Standard Orders (ETSOs) and other regulatory documents.EUROCAE works with US standardisation bodies to produce harmonised specifications where possible.EUROCAE documents also take into account ICAO standards and ARINC specifications.

Eurocontrol—the organisation for the harmonisation of air navigation services across Europe. It is a civiland military inter-governmental organisation, currently with representation from 38 Member States. Itsmission is to harmonise and integrate air navigation services through a uniform Air TraYc Management(ATM) system for civil and military users. Implementation will include a system known as the SingleEuropean Sky (SES). Eurocontrol is based in Brussels, Belgium, and has oYces in six other Europeancountries.

FLARM—A proprietary GPS-based short-range proximity-warning system for light aircraft, gliders andother sport aircraft, developed by the Flarm company of Zurich, Switzerland, using frequencies in the 800MHz band. The name is taken from the words FLight AlaRM. It transmits the GPS position and pressurealtitude of the own aircraft (the “ownship”) to other Flarm-equipped aircraft and displays proximityinformation in a cockpit indicator and also through cockpit audio. It was originally developed for flightsover the Alps but has worldwide applications. It uses the Swiss uBlox TIM-LP 16-channel GPS receiverboard. An ADS-B-compatible version is being developed. See www.flarm.com

SESAR—Single European Sky Air TraYc Management (ATM) Research Programme. This is aEuropean-wide ATM improvement programme involving civil and military, legislators, industry, aircraftoperators, ground and airborne users. It also supports Single European Sky (SES) legislation. SESARobjectives include transforming the European ATM system, eliminating the previous fragmented approachto ATM across European Nations, synchronising plans of the diVerent partners and pooling of resources.SESAR is being run in three major phases: 2005–08, Definition Phase; 2008–15, Development Phase;2014–20, Deployment Phase. The equivalent programme in the USA is called NextGen.

Annex C

EXTRACTS FROM U.S. FEDERAL AVIATION ADMINISTRATION (FAA)NOTICE OF PROPOSED RULEMAKING (NRPM) 7–15, ISSUED IN WASHINGTON, DC,

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Annex D

GENERAL AVIATION AIRCRAFT OPERATING IN UK AIRSPACE

Source: GA Alliance P-RIA response to the CAA, para 3.5.1 GA compared to total UK aircraft % about 96%The numbers are mainly from CAA reviews of UK General AviationListed in numerical order of aircraft numbers, Aeroplanes & Helicopters first

Class Numbers % % Remarksof UK total of GA

Aeroplanes (GA types) 8,900 32.9 34.3 Excludes microlights (included below)Helicopters & Gyroplanes (GA types) 1,560 5.8 6.0 Includes 250 GyroplanesHang gliders & Para Gliders 5,960 22.0 23.0Microlights 4,100 15.2 15.8Gliders, SSGs*, SLMGs** 2,540 9.4 9.8 CAA figures do not include TMGs***Balloons & Airships 1,850 6.8 7.1Powered Hang Gliders & Para Gliders 1,050 3.9 4.0Totals 25,960 96.0 100.0Excepting aeroplanes & helicopters 15,500 57.3 59.7 Could be regarded as Sport Aircraft totalLittle or no electrical generation 13,450 49.7 51.8 Hang/Para Gliders, half of Microlights, Gliders & Motor Gliders**,

Balloons, Powered Hang GlidersThose without any electrical generators 10,350 38.3 39.9 Hang/Para Gliders, Gliders, BalloonsBGA Sep 2006 club returns 2,511 9.3 9.7 Gliders

62 0.2 0.2 SLMG112 0.4 0.4 Tugs

Total BGA 2,685 9.9 10.3 BGA operated aircraft 2007Total gliders 2,573 9.5 9.9 BGA gliders & MGs

* Self-Sustaining Gliders (SSGs) have small engines and no electrical generation- The engine cannot be used for takeoV but is used to save from field landing** SLMGs have electrical generation but only run the engine for initial takeoV and climb and to save from field landing -- Typically 10 minutes of engine in a 5 hour soaring flight*** Touring Motor Gliders (TMGs) have the engine in the nose and can be operated either as a motor glider or as a lightaircraft in motor glider mode they will spend long periods soaring without engine

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Memorandum from Birmingham International Airport (AIR 47)

Background

1. Birmingham International Airport welcomes the opportunity to contribute to the Inquiry into the useof Airspace.

2. Birmingham International Airport employs NATS to undertake air traYc control at, and in theairspace surrounding, Birmingham Airport.

3. The airspace serving Birmingham International Airport is located between some of the busiest andmost congested volumes of airspace in the world. The London Area controlled airspace to the south andthe Manchester Area controlled airspace to the north already, on occasions, place restrictions on the abilityof Birmingham International Airport to operate punctually. The high degree of utilisation and congestionresults, occasionally, in the imposition of departure flow restrictions on air traYc leaving BirminghamInternational Airport.

4. Birmingham International Airport has a significant role to play in providing additional airportcapacity for the United Kingdom, as set out in the 2003 White Paper—The Future of Air Transport(ATWP). Birmingham International Airport’s overriding concern is to ensure that future capacity growthof the Airport is matched by growth within the local and national airspace environments. Furthermore, thatchanges in the structure and management of United Kingdom en route airspace is fully co-ordinated withairports and other airspace users, within the context of a comprehensive framework.

5. Birmingham International Airport has submitted a planning application for a runway extension andassociated infrastructure and the Local Planning Authority, Solihull Metropolitan Borough Council, isminded to approve the planning application, subject to final agreement on a Section 106 PlanningAgreement. The final planning decision is expected in March 2009. Birmingham International Airportwould then commence a detailed CAP 725 Airspace Change Process (ACP) with regard to airspace changesresulting from the planning application to extend the runway. Therefore, it would be premature to commentfully to the Select Committee on the process, but certain key issues are highlighted.

6. The response to questions raised by the Transport Select Committee are shown below.

Question 1 What changes to the management of airspace could be required as a result of the additional airportcapacity outlined in the 2003 White Paper? Are the White Paper’s projections for increased passenger demandstill accurate? Are all the measures to provide for increased passenger demand likely to be implemented?

7. The forecasts in the ATWP have been shown to be relatively robust, with only a slight reduction for2030 in the latest DfT forecasts. Birmingham International Airport’s Master Plan forecasts of 32.6 mppaby 2030 in the ATWP have now been revised to a figure of 27.2 mppa by 2030.

8. The ATWP and the ATWP Progress Report (December 2006) are very clear that a structuredprogramme for the redesign of UK airspace is required to accommodate the forecast increase in AirTransport Movements (ATMs) by 2030. The Civil Aviation Authority (CAA) is responsible for the planningand regulation of UK airspace, but will involve NATS and other interested parties.

9. It is worth noting that a specific responsibility of the CAA Directorate of Airspace Policy (DAP) is“Preparation and maintenance of a co-ordinated strategy and plan for the use of UK airspace and for airnavigation” (Airspace Charter CAP 724).

10. Although Birmingham International Airport is committed to providing the infrastructure necessaryto meet the anticipated growth in passenger volumes, it is concerned that there is not yet a robust nationalplan in place to deliver the airspace capacity growth in line with projected airport capacity growth.

Question 2 Can safety be maintained as airspace is increasingly utilised? Is there a suitable interface betweenmilitary and civilian arrangements for air traYc control?

11. The Airspace Charter (CAP 724) states the role of the DAP as “To ensure that UK Airspace is utilisedin a safe and eYcient manner”. Likewise, NATS is required under its licence from the CAA to ensure thesafety and eYciency of the UK airspace system. Therefore, it is appropriate for CAA/NATS to advise onthis issue. Birmingham International Airport expects that safety can, and will, be maintained within UKairspace, but has no specific expertise in this area. Likewise, Birmingham International Airport holds noviews on the question of military and civilian air traYc control interfaces.

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Question 3 Is the current approach to planning and regulating the use of UK airspace adequate? Would anAirspace Master Plan covering the period of the White Paper be beneficial? Could a piecemeal approach toindividual developments necessitate additional redesigns subsequently?

12. A structured programme for redesign, as suggested in the ATWP, is required. However, an “AirspaceMaster Plan” would probably be too detailed and could be inflexible, but there does need to be a morestructured approach compared to the current piecemeal approach.

13. Birmingham International Airport would view favourably a structured programme to co-ordinatechanges in the management of neighbouring volumes of airspace that cause “knock on” changes to be madeto airspace serving airports. The current piecemeal approach to airspace redesign occasionally results inredesign projects in airspace adjacent to that of Birmingham, requiring changes to the design of the airspaceserving Birmingham.

14. As previously mentioned, it is too early to be commenting on a revised Airspace Change Process(ACP) (which was only introduced by the CAA in March 2007), bearing in mind that BirminghamInternational Airport is only part way through an ACP regarding a proposed change to flight paths resultingfrom the runway extension.

15. However, it is evident that where an airspace change is due to a change in infrastructure on the ground,such as a runway extension or new runway, then the ACP potentially presents a huge commercial risk toairport operators. DAP approval comes very late in the process, typically an airport company would haveto commit to significant capital expenditure at some risk as the required DAP approval typically, would notbe forthcoming until construction is either well under way or completed.

16. This is potentially an unacceptable risk to shareholders and a way has to be found of changing theACP, when major infrastructure on the ground is involved, which enables approval to be obtained at anearlier stage, hence reducing commercial risk without undermining the comprehensive and appropriatenature of the consultation process.

Question 4 How are the eVects and aircraft noise and emissions taken into account when changes are made tothe use of airspace? Who should be consulted about such changes? How should the balance between conflictinginterests be struck?

17. Detailed requirements on assessing the environmental impacts are laid down in CAP 725 CAAGuidance on the Application of the Airspace Change Process (March 2007). These requirements are alreadyvery complex and comprehensive and should not be added to.

18. Ultimately, it is the CAA’s role to approve airspace changes and it is appropriate that the CAA retainthis responsibility which includes assessing conflicting interests.

Question 5 How does the management of airspace in the rest of Europe aVect flights into the UK? Is therean opportunity to integrate our plans for changes to airspace management more eVectively with those of otherEuropean countries?

19. No comment—for CAA/NATS to advise.

Question 6 What opportunities are there to apply new techniques and technologies to reduce wasteful flyingon indirect routes and excessive “stacking” while planes wait to land? How can the potential of any suchopportunities best be realised? Could environmental benefits be gained as a result of such improvements?

20. Detailed questions on new techniques and technologies are best answered by the CAA, NATS andairlines. Environmental benefits will result from a reduction in stacking and flying reduced distances.However, as a general point, there needs to be a co-ordinated approach through a structured programmefor redesign, as discussed in Q3 above. The “Sustainable Aviation” programme (of which BirminghamInternational Airport is a signatory) provides a good approach to co-ordinated action. An example ofContinuous Descent Approaches being introduced does show that noise and emissions can be reduced.

21. An example of new technology being applied is the design of new Standard Instrument Departureroutes, in relation to Birmingham International Airport’s proposed runway extension, using PR-NAV(Precision Area Navigation), but clearer guidance is required from the DAP as to what future navigationdesign/procedures should be.

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Transport Committee: Evidence Ev 247

Question 7 In relation to the redesign of UK airspace, is the allocation of the roles and responsibilities of eachof the interested parties—Department for Transport, the CAA, airport operators, NATS, etc—appropriate andclearly understood? Are the structures of the parties appropriate for undertaking the roles that they should play?

22. Roles and responsibilities are clearly stated in CAP 725 and these are primarily stated as the CAA(Department of Airspace Policy), ANSPs (Air Navigation Service Providers such as NATS) and airportoperators. In reality, airport operators will rely heavily on the advice and expertise of the CAA and ANSPsas they would not have the in-house expertise to carry out an airspace design change.

Question 8 Do airspace management considerations delay the planning processes in relation to airportdevelopment proposals? How will airspace management considerations be taken into account by the proposednew Infrastructure Planning Commission and the relevant National Policy Statements on airport planning?

23. The Airspace Change Process should be considered in the context of strategic airspace designdecisions and it is correct that the responsibility for the planning and regulation of UK airspace lies withthe CAA and not with Local Planning Authorities. Provided that airspace change issues are considered aspart of the CAP 725 Airspace Change Process, which can run in parallel to but not as part of the planningprocess, there should, in theory, be no delay to airport development through the planning process. However,the ACP does have the potential to delay the provision of infrastructure after the planning process iscomplete and, in extreme cases, result in a redesign, further consultation and consequently significant overalldelay to infrastructure development projects.

Question 9 What could be the implications for smaller airfields, recreational flying and helicopters of changesto airspace management to enable safe and eYcient increases in capacity at the UK’s major airports? Howshould an appropriate balance between conflicting priorities be determined?

24. No comment.

Question 10 Will it be possible to recruit and train staV in order that airspace changes can be implemented inparallel with additional airport capacity?

25. No comment—for CAA/NATS to advise.

Question 11 Who should fund airspace changes? Is there likely to be enough funding to undertake the redesignrequired to bring about the necessary additional airspace capacity?

26. Airports already fund airspace changes required as a result of infrastructure improvements—including the undertaking of relevant impact assessments and public consultation. General en-routeairspace redesign should be funded by Government through the CAA or NATS, whichever is deemed mostappropriate.

March 2009

Joint memorandum from the General Aviation Alliance and the Light Aircraft Association (AIR 48)

1. This paper on the use of airspace by General Aviation Alliance (GAA) and the Light AircraftAssociation (LAA) supplements that presented on 28 Feb 09 to the Inquiry into the future of aviation bythe GAA (attachment). That paper set out the size, value and scope of GA whilst this paper explains theairspace issues relevant to it. The GAA is a group of organisations representing the interests of many in theUK General Aviation Industry (GA). The LAA is an organisation which supports aVordable flying and isthe focus of amateur built aircraft in the UK. It is a member of the GAA.

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Ev 248 Transport Committee: Evidence

commercial non-GAaircraft

4%

“traditional” single-engined piston

21%

multi-engined piston andlarger singles

2%turbine

1%helicopters and

gyroplanes6%

vintage and historic2%

amateur-built(fixed-wing)

6%

microlights15%

gliders(including SLMG)

10%

hang gliders & paragliders(including powered)

26%

balloons and airships7%

Make- up of UK GA, 2005

2. GA is the term used for all aircraft and flying machines other than those operated by airlines. GAranges from privately owned Airbus and Boeing aircraft and business jets to balloons, light aircraft, glidersand para-gliders. Its aircraft are used for business, training, recreation, sport and pleasure and as a meansof transport.

3. The GA sector comprises about 26,000 of the 27,000 aircraft on the UK register, the remaining 1000belonging to airlines—see the Civil Aviation Authority (CAA) chart at right. GA employs some 17,000people and has a value to the economy around £1.4 billion, about the same as Virgin Atlantic Airways or8% of the total economic contribution of UK commercial aviation.

4. GA aircraft use all types of airspace: business and some private aircraft mainly use controlled airspacebut the majority used for recreation and sports remain in uncontrolled (class G) airspace but need to crosscontrolled airspace on occasions.

As we noted in our submission on “The Future of Aviation”, the issue of the use of airspace was coveredin much detail in the CAA’s Strategic Review. Section 3.1 of the report neatly summarises the problem:

“As with all forms of aviation, GA needs a certain level of access to infrastructure in order tooperate, although this may vary widely across the diVerent types of GA.

There are two main infrastructure issues: airfields (or some form of fixed site to take oV and land): andaccess to airspace. GA is currently facing increased diYculty in accessing both of these, particularly in themore congested areas of the UK.”

This situation prevails and is becoming, and forecast to become worse due to growth in demand forcontrolled airspace from Commercial Air Transport (CAT), more controlled airspace around airports andnew reserved airspace for unmanned aerial vehicles, the latter both from Ministry of Defence and privatecontractors.

Executive Summary

— Number of flights in the UK has not increased as much as commercial operators suggest.

— Controlled airspace (CAS) has expanded significantly and continues to do so:

— Parts of it are barely used but are not given up.

— The CAA appears to have a conflict of interest arising from the Civil Aviation Act 1982.

— GA wants to integrate safely without disproportionate restrictions.

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— Sponsors of CAS applications tend to ignore the impact on other airspace users:

— This produces an adversarial relationship rather than cooperation for safety.

— Increased CAS forms choke points and forces GA aircraft lower increasing intrusion.

— Continuous Descent Approaches (CDA) reduce noise and the need for lower level CAS:

— But airspace is rarely given up.

— Spread of CAS threatens GA airfields, an issue which the CAA recognises:

— CAA has no statutory remit to defend GA infrastructure and does not do so.

— Flexible Use Airspace (FUA), which is used in the EU, would help share important areas.

— Airspace safety information is not “user friendly” but CAA and NATS decline to change.

— Airprox (close encounters) numbers are very low. In last reporting period:

— None in the UK involving actual risk of collision.

— Only two involving GA/CAT where safety was compromised:

— One when CAT flying outside CAS

— One inside CAS when both aircraft under ATC control (inadequate separation).

— Sky is important national asset

— Commercial organisations now sponsor and control CAS:

— NATS is powerful and owned by shareholder airlines.

— CAA has statutory duty to support UK airlines.

Changes to Management of Airspace

5. The inquiry notes that UK passenger numbers may double over 25 years and that UK airspace,particularly in the south will need redesign. Although airport developers like to use passenger numbers tohighlight business growth, aircraft are getting larger and airspace demand is dependent on aircraft notpassengers. CAA statistics (Annex A) show that passenger numbers have grown 48% in 10 years but flightsby only 29%. Moreover there has been no aircraft growth since 2006 and recent figures are down significantly.This suggests growth and capacity projections for commercial airports are wrong and are not a valid basisfor airspace planning. However, developers continue to use these figures for their own purposes.

6. The CAA report that in 1997 controlled airspace covered 13% of the UK and in 2004 this had risen to20%. We understand that the CAA is about to produce a current figure but since 2004 there has beensignificant growth in controlled airspace at major airports and particularly at regional airports.

Safety through Co-operation

7. The GA community is a responsible stakeholder in UK airspace and has a good record of integratingsafely with other airspace users. Our experience is that safety can be maintained through co-operationbetween airspace users, avoiding the need to exclude GA from large areas or to force disproportionate andimpractical technology solutions.

Airspace Planning and Regulation

8. The current Airspace Change Process managed by the CAA backed by regular liaison of allstakeholders and with ATC authorities is generally satisfactory. It ensures all stakeholders are able toscrutinize proposals and express their views before the CAA makes a decision. However we would drawattention to a possible conflict of interest within the Sponsorship Statement for the CAA (verbatimextracts follow):

The Civil Aviation Act 1982 requires the CAA to perform its functions in the manner it considersbest calculated:

“to secure that British airlines provide services which satisfy all substantial categories of publicdemand …., at the lowest possible charge consistent with a high standard of safety in operatingthe services and an economic return to eYcient operators on the sums invested in providing theservices and with securing the sound development of the civil air transport industry in the UK; andto further the reasonable interests of users of air transport services”.

Later in the Act it is stated that (the CAA) has a function to :

“determining policy for the use of UK airspace so as to meet the needs of all users, having regardfor national security, economic and environmental factors, while maintaining a high standard ofsafety”.

Lord Turner, commenting on his recent review of the banking industry noted that “…a regulator whichhas a statutory duty to one part of the industry it regulates clearly has a conflict of interest”.

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Ev 250 Transport Committee: Evidence

We have heard it stated within the CAA that it takes the view that Government has determined the publichas a right to fly (via commercial air transport), and if that means more airspace has to be classified as“controlled” thereby limiting the amount freely accessed by GA, then so be it. This policy tends to supportour view that balance is not achieved. We also understand that Government may be about to review the CivilAviation Act.

Although an Airspace Master Plan might be important for en-route airspace, at lower levels, specificindividual consultation ensures the balance between business growth, the environment and other airspaceusers. A pre-approved master plan would remove the check and balance and make consultation less eVective.

The Environment

9. Compared to the airline industry, GA has only a minor impact on the environment. Its emissions, noiseand visual intrusion are small and it seeks to minimize its impact wherever it can. GA airfields and flyingsites always try to be good neighbours but changes to airspace can and do have a negative impact. Becausemost GA aircraft cannot fly in controlled airspace they have to route around or below it. Where controlledairspace is expanded or new airspace introduced it forces them closer to the ground increasing their noiseand visual intrusion. It often causes congestion as aircraft are funnelled through choke points betweencontrolled and restricted airspace blocks increasing risk and intrusion. For this reason we seek to minimizethe expansion of controlled airspace into areas where this would be a problem but the interest of commercialoperations usually prevails.

Aircraft Equipment

10. The CAA has an aspiration to impose radar-based Mode S transponder devices on every aircraftflying anywhere in UK airspace. These make the aircraft identifiable to radar systems and to anti-collisionsystems installed in airliners and are mandatory for public transport aircraft flying in controlled airspace.The majority of GA have no right to fly in controlled airspace and generally do not do so. They are able toenter and cross it with specific ATC permission and under control. For visual flight outside controlledairspace where CAT aircraft are generally not encountered, imposition of Mode S was strongly resisted byall UK air sport associations because the equipment is expensive in relation to the hull value of many smallaircraft and a many thousands of aircraft have no electrical system to support transponders. Whilst the useof Mode S radar transponders in Commercial Air Transport aircraft flying in controlled airspace is vital tosafety (it is a part of the anti-collision system of last resort) it does not benefit small aircraft which do nothave the complex anti-collision systems needed to see other transponders and resolve conflicts. Althoughthere are exceptions, in general GA aircraft fly outside CAS and CAT flies within it. Thus the overwhelmingmajority of GA aircraft never encounter CAT aircraft.

11. Presently, the carriage of transponders is mandatory everywhere in the UK above 10,000ft and thishas not been an issue as most GA aircraft do not use that airspace. Gliders do need to fly above 10,000 ftbut because of their particular problem of weight, space and power supply they have been exempt but theCAA has now proposed to remove that exemption. This would stop a significant part of the sport whichrequires cross country racing often above 10,000 ft and destroy the UK’s competitive position in Worldrankings. Essentially, air sport needs access to the equivalent of Green Belts in the sky and although thecommunity is looking for assurance from the CAA that access will be provided, this has not beenforthcoming.

Techniques and Technologies

12. The introduction, over the last five years, of Continuous Descent Approaches (CDA) brings airlinersdown a 3 degree flight path (310ft per nautical mile) all the way from their cruising altitude to touchdown.Their engines remain virtually at idle throughout reducing noise and emissions and providing substantialfuel and cost savings. This has advantages for the population and for GA because airliners are higher (andquieter) and do not need so much low level controlled airspace. At the same time, the technology availableto ATC controllers has enabled them to achieve more eYcient routing and to increase the landing and take-oV rate so better utilizing our existing runways.

13. Although this should have resulted in the release of controlled airspace, in practice National AirTraYc Services Ltd (NATS) and other ATC providers want to retain this resource because there is nobusiness advantage in giving it up and they are operated very much as businesses. For example, using CAAdata and charts we find that Gatwick is very eYcient in its use of airspace using only some 1.8 sq km forevery 1000 aircraft movements. Glasgow has three times the controlled airspace of Gatwick with only a thirdof the number of flights but NATS (who operate that airspace) have said they cannot consider releasingunused areas and are presently bidding for a 50% increase. Doncaster has recently been awarded controlledairspace slightly larger than Gatwick but has only 2% the number of flights at Gatwick. We would like tosee a proper balance in allocating controlled airspace to airports but business interests work against that. Itis clear that NATS and other ATC providers are now very business focused and powerful and see airspaceas an asset to be acquired and retained.

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Airspace Planning and Management

14. GA organisations work together to engage with CAT operators, with NATS and the CAA and otherairspace stakeholders to try to ensure equitable access to airspace. Although we are able to respond toairspace consultations we are usually in the position of challenging a proposal which has been put togetherwith little regard for the impact on GA. We would rather work together with airspace sponsors during theearly stage of the airspace change process to develop a design that meets the operational and safety needsof all airspace users rather than engage in adversarial debate at a later stage. We recognise that the safetyof public transport flights must be assured but there are always diVerent ways to achieve that and we lookto eYcient and eVective solutions that allocate controlled airspace that is necessary and suYcient for therequirement.

15. We have seen airspace applications where the object appears to be to secure as much of this freeairspace resource as possible to increase the capital value of the sponsor’s business. This would be easilyidentified by an objective, rigorous and detailed risk analysis which should always take place before anyincrease in Controlled Airspace is agreed. But surprisingly, risk analysis is not a tool widely used in airspacematters by controlled airspace sponsors and seemingly not by the CAA.

Airspace Implications for Smaller Airfields

16. As the main airports have approached capacity and driven by airlines’ search for more business andcheaper landings, regional airports have seen an upsurge in the last five years. This has seen a proliferationof controlled airspace proposals around the country which the CAA has always approved, although withsome mostly minor, modification. Controlled airspace now divides the country between the Mersey andHumber with just two access routes north to south. A narrow corridor is defined between Manchester andLiverpool in which GA aircraft have to fly at only 1000ft above the ground and a wider area to the east ofDoncaster which is under threat from a bid for airspace from Humberside. There is nothing in between. Incentral Scotland, controlled airspace extends from the Clyde to the Forth with a corridor between Glasgowand Edinburgh which NATS is now proposing to take for itself, isolating the Highlands from the south foraircraft which are unable to cross controlled airspace and excluding gliders from prime soaring country inthe Borders and Highlands. We noted earlier that Glasgow had 3 times the controlled airspace of Gatwickwith only one third of the flights.

17. With airports focusing on business and many excluding GA, small airfields, airstrips and gliding sitesare a limiting resource to the community. The spread of controlled airspace restricts the use of many smallairfields and strips and it is virtually impossible to relocate as communities always fear a small and quietoperation will develop into noisy jet traYc. Our only recourse is to negotiate with airspace sponsors for anagreement to continue access although that often means flying low or in areas we would normally avoid forsafety or environmental reasons. We would like to see a better balance achieved by giving appropriate regardto small airfields and including access arrangements and risk analysis at the time airspace is designed.

Flexible Use of Airspace

18. Flexible Use Airspace (FUA) is airspace that is turned oV or on at specific times to meet traYc needs.Currently this occurs in upper airspace allowing short cuts for commercial aircraft when military traYc isnot using certain areas. We would welcome built-in flexibility when developing lower airspace, for examplegiving access to an area that is not needed when a particular runway is being used. This is common elsewherein the EU.

Presentation of Airspace Safety Information

19. One of the key aspects of airspace is notification so that pilots know where they can and cannot fly.Controlled and restricted airspace changes daily and details are distributed by NATS through Notices toAirmen (NOTAM) which also includes a plethora of other information related to navigation aids and soon46. Airlines have contractors who compile and sift this for their crews but individual GA pilots must workwith the raw data themselves. As responsible airspace users, many pilots bought graphical programs thatwould sort and present the data pictorially so they could relate airspace changes and prohibitions to theirroute but the NATS NOTAM website format was changed without consultation making these programsuseless. Pilots now have to work with pages of text and plot multiple positions manually increasing risk ofmistake and forming a major disincentive to meticulous pre-flight planning. This is a particular problem forgliding as cross country routes must follow the energy in the atmosphere so their route cannot be plannedin specific detail before flight. The CAA contracts NATS to distribute NOTAMs in the UK but neither body

46 The General Aviation Alliance provided a copy of an example of NOTAM information for a short VFR flight from Elstreeaerodrome (just North of London) to Coventry for 1 April 2009. The document is 22 pages long. The GAA said theinformation provided in the Notice covered a much greater area of the country than was really required for that particularflight, and the areas aVected by each Notice were defined by latitude and longitude references which made it diYcult tointerpret and required much time to deal with.

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Ev 252 Transport Committee: Evidence

will provide this data in a suitable graphical format saying the cost is prohibitive. But they have been unableto say what that cost is. We think this a significant airspace safety issue that the CAA could resolve but saysit will not.

Low Risk and Proportionate Burdens

20. There is no doubt that there is a need to ensure all aircraft can operate safely within UK airspace. Itis testament to the excellent work and risk mitigation by all stakeholders that Airprox (reported closeencounters between aircraft) involving light aircraft or gliders (or military aircraft) and commercial airtransport (CAT) are at a very low level. The UK Airprox Board in its 20th report notes that in the first halfof 2008, GA were involved in only 34% of airprox compared to 50% in 2001. In that period there were noAirprox involving “actual risk of collision” anywhere in the UK and of the two incidents involving GA andCAT where “safety was compromised”, one involved a CAT aircraft flying outside controlled airspace andthe other involved inadequate separation when both aircraft were under ATC control within controlledairspace. Operating safely includes of course the need for all pilots to be in flying practice. Increasing coststo those whose aviation activities are taxed, severely limiting access to the sky and developing increasinglyover-complex and occasionally confusing regulatory burden results in reduced flying practice and therebydoes nothing to increase safety.

21. The sky is an important national asset. With sponsorship and management of controlled airspacebeing in the hands of business entities and particularly with NATS being so powerful in this area andresponsible to its shareholder airlines for delivering their requirements, the Regulator must be proactive andmeticulous in balancing the needs of all airspace users. We believe that at the moment the sponsors ofcontrolled airspace give insuYcient regard to the needs and safety of other airspace users and whilst the CAAis required to determine policy so as to meet the needs of all users, it appears to have a conflict of interestarising from its duties under the Civil Aviation Act 1982.March 2009

Annex A

TOTAL UK TERMINAL PASSENGERS 1998 TO 2008—SOURCE CAA STATISTICAL TABLES

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

161M 170M 182M 183M 191M 202M 218M 230M 237M 243M 238M

300000000

250000000

200000000

150000000

100000000

50000000

0

98 99 00 01 02 03 04 05 06 07 08

Passenger growth48% in 10 years

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Transport Committee: Evidence Ev 253

TOTAL UK AIR TRANSPORT MOVEMENTS 1998 TO 2008—SOURCE CAA STATISTICALTABLES

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

1.9M 1.9M 2.0M 2.1M 2.1M 2.1M 2.2M 2.4M 2.4M 2.4M 2.4M

3000000

2500000

2000000

1500000

1000000

500000

0

98 99 00 01 02 03 04 05 06 07 08

Flight Growth29% in 10 years

Annex B

THE GENERAL AVIATION ALLIANCE (GAA)

The General Aviation Alliance (GAA) is a group of organisations representing the interests of many inthe UK General Aviation Industry (GA). It was formed in 2004 due to concerns about the fragmentedrepresentation of GA and the need for co-ordinated UK level responses to CAA and EU initiatives, the latterthrough a pan-EU representative organisation, Europe Air Sports.

The term General Aviation (GA) describes all aviation activity except airlines and military ie a civilaircraft operation other than a commercial air transport operation. The principal sectors of the GA industryinclude sport and recreational aviation (S&RA), personal transport for business and private purposes, flyingtraining, corporate aviation, aerial work and a wide range of ancillary activities from maintenance to airportservices. There are approximately 7,500 UK registered and certificated (including approximately 1,000helicopters) plus 1,000 USA registered GA powered aircraft in the UK, 2,300 microlights, 2,600 gliders, 740balloons/airships, 62 gyroplanes plus 5,500 hang and paragliders and approximately 1,000 UK civil airliners.In addition parachuting activities are within the scope of CAA regulation as well as aero-modelling.

It is understood that air shows are now the UK’s second most popular spectator activity with some 6.6mattending annually (Source: Air Display Association (Europe)).

Members of The Alliance include:

British Balloon and Airship Club (BBAC)

British Gliding Association (BGA)

British Hang Gliding and Para Gliding Association (BHPA)

British Microlight Aircraft Association (BMAA)

British Parachute Association (BPA)

Helicopter Club of Great Britain (HCGB)

Light Aircraft Association (LAA)

PPL/IR Europe—European Association of Instrument Rated Private Pilots

Royal Aero Club of the United Kingdom (RAeC)

The Alliance coordinates about 72,000 subscription paying members of these bodies.

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Ev 254 Transport Committee: Evidence

Annex C

THE LIGHT AIRCRAFT ASSOCIATION (LAA)

The LAA is a national association of some 8000 members which promotes safe and economical operationof Sports and Recreational aircraft, with minimum regulation, through excellence in:

Promotion of amateur aircraft construction

Provision of aircraft engineering support

Protection of flying rights and ownership

Preservation of vintage aircraft

Discharge of regulatory duties

Encouragement of pilot training and skills

Promotion of public opportunities to experience aviation

We promote aviation to the general public through practical educational experiences including Build-a-Plane projects where groups of young people participate in the construction of a kit aircraft and are thenable to fly in it. We also oVer youth air experience events and training in both flying and engineering skillsas well as promoting “air mindedness” wherever we can.

The LAA is the UK focus for amateur built aircraft, operating a delegated regulatory system enablingmembers to design, build, maintain and fly their own aircraft. Many members build aircraft from kits orfrom plans; there are about 2000 aircraft under construction in the UK at any time. The LAA also supportsmany vintage aircraft which might otherwise be lost to our national heritage. Our goal is to bring low costflying within the reach of anyone who has the desire to fly.

The LAA regulates the airworthiness of over 2000 recreational and homebuilt aircraft on behalf of theCAA, and currently has over 280 diVerent aircraft types and models on its approval. It is possible to owna simple aircraft for little more than £5,000 or a share in a more complex aircraft might only cost £1,000 orso. Maintenance can be carried out by the owner under the supervision of the LAA’s extensive network ofexperienced inspectors enabling operating costs to be very low. To manage the operation and safety of thislarge spectrum of aircraft the LAA maintains a substantial professional engineering department withspecialist and unique aeronautical skills.

Born as the Popular Flying Association in 1952, the present LAA continues to bring flying within thegrasp of everyman.

LAA pilots operate mainly in day visual conditions but its aircraft fleet ranges from historic examples tomodern high performance aircraft with sophisticated navigation systems. Pilot experience and qualificationalso covers the full spectrum of professional and amateur. The LAA has a high regard for air safety andtakes a broad view on airspace matters generally. In considering airspace change proposals we recognise theimportance of public safety and place that first but in line with Government and CAA policy we expectairspace to be utilised in a safe and eYcient manner taking into account the needs of all users.

March 2009

Memorandum from the British Business & General Aviation Association (AIR 49)

As part of your wider engagement with stakeholders, I am pleased to take this opportunity to submitwritten evidence on behalf of the 170 members of the British Business & General Aviation Association(BBGA).

The BBGA’s members are engaged in a wide variety of activities within the General Aviation sector;including the operation of aircraft, maintenance, handling, airfield operation and insurance, among others.

Our aircraft-operating membership is almost exclusively made up of companies which use their aircraftas workhorses; either to train pilots or as a means to increase the eYciency of their own or their client’s mainbusiness. The businesses that our members operate are not extravagant or run on a “money-no-object”basis; they are businesses operating on margins comparable with other areas of industry, and eithercompeting against foreign companies for work throughout Europe, or using their aircraft as a productivitytool for their own management team. A European Commission paper entitled “An Agenda for SustainableFuture in General and Business Aviation” published on 11 January 2008 has been provided to Governmentpersonnel and gives an idea of the important role which the commission recognises is performed by Generaland Business Aviation.

The 2003 White Paper understandably focused on the role of Air Transport in an ever more congestedworld. Looking back at the document today, it is apparent that the role of Business & General Aviation wasin a large part overlooked. During the same time period, valuable Business & General Aviation hascontinued to be displaced from congested hubs in favour of scheduled Air Transport services, on the

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Transport Committee: Evidence Ev 255

principle that “a full aircraft is an eYcient aircraft.” BBGA takes issue with this underlying sentiment, andbelieves that the United Kingdom needs to start challenging these perceived truths, and start to legislate toprotect access to scarce resources by all users.

There is a consultation currently concerning the likelihood of London City Airport, a key BusinessAviation hub, becoming fully co-ordinated. This will have direct impact on the City of London and ourcountry’s ability to generate wealth as we seek to recover from the present economic downturn. Luton isnext, where today Business Aviation traYc makes up more than 22% of the movements. The large air carriersand the operators of the airport terminal shopping malls have scored a march on the small but comparativelyfar more valuable Business Aircraft user, and it is important to redress this imbalance. It seems anachronisticthat a scheduled carrier laden with party-goers destined for a cheap weekend in Prague should have the legalright to displace traYc of far greater net worth to the British economy, but that is the case today.

In terms of airspace utilisation, our membership is ready and equipped to take advantage of the latesttechnologies and infrastructure improvements. These changes typically occur at a much slower pace thanwe would like. The introduction of 8.33kHz spacing for VHF comm radios is a case in point: All aircraftabove FL245 have been required to carry this equipment in Europe since 1999, and yet the first UK 8.33kHzfrequency was not introduced until 2005. Time and again, it seems as if the users are forced to “invest” ininfrastructure improvements, which for one reason or another turn out to be illusory at best or non-existentat worst. The current SES programme is vital for European airspace eYciency, and should be acceleratedby EU Member States.

Summary

UK Aviation policy has been inattentive to the needs of Business and General Aviation for too long. Toredress this imbalance, BBGA makes twelve key recommendations, as follows:

1) Economic value (including induced value) should be at the heart of every UK aviation policydecision.

2) Congested UK airspace should be addressed in an integrated fashion with those of its neighboursto enable rapid eYciency improvements.

3) Business & General Aviation should be given access rights to scarce resources which could then inturn be used as a model to protect low-cost carriers as Cap and Trade starts to impact theirbusiness model.

4) Airport capacity limits should be set with the primary aim of maximising the eYciency of the AirTraYc System.

5) A systematic, cross-functional approach to airspace safety should be undertaken, with a data-driven approach to improving safety statistics.

6) The United Kingdom should re-double its eVorts to drive up European Airspace eYciency metricsthrough the SES programme as executed by EuroControl.

7) The UK government should make it clear to the electorate that “lifestyle” consultation responseswill be of progressively lower value in the decision process in order to speed up attainment ofenvironmental goals.

8) Government should speed the IPC and give it a clear brief including strategic principles forGeneral Aviation and associated assets.

9) The UK should adopt a clearer, risk-sharing, approach to airspace eYciency initiatives, with theUK provider bearing financial risk in the event that promised eYciencies do not materialise despiteinvestment by users and the agencies concerned.

1. What changes to the management of airspace could be required as a result of the additional airport capacityoutlined in the 2003 White Paper? Are the White Paper’s projections for increased passenger demand stillaccurate? Are all the measures to provide for increased passenger demand likely to be implemented?

Business Aviation comprises about 8% of Instrument Flight Rules (IFR) traYc in Europe. Recently, aCommunication from the European Commission entitled “An Agenda for a Sustainable Future in Generaland Business Aviation” dated 11 January 2008 COM (2007) 869 Final stated that “General and BusinessAviation provides closely tailored, flexible, door to door transportation for individuals, enterprises and localcommunities, increasing mobility of people, productivity of businesses and regional cohesion”. As such,Business & General Aviation operates from a range of airports and aerodromes transporting people andgoods directly between the two ends of their journey. For Business Aviation to function eYciently, it musthave equitable access to all airports and the airspace must be managed with maximum eYciency as its goal.And yet, in the UK we see airport capacity limits being set no in relation to what makes sense from anairspace design point-of-view, but purely from the point-of-view of what makes sense to people living aroundan airport. The recent decision backing the expansion of Stansted Airport, General Aviation less than 10seats was handed an arbitrary limit of 10,000 movements which was inserted by local government

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representatives without consultation and without any clear reason for doing so. That GA can bemarginalised at the hands of local government without the DfT being aware is a result of not having aninclusive plan for access to scarce resources by all forms of aviation.

In the mid-term, it seems unavoidable that significant investment will have to be made to improve theeYciency of some UK airspace nearing its capacity limits. For example the London TMA is already at itslimits at some periods. Single European Skies is designed to improve the interoperability of adjacent airspaceblocks, and it seems sensible to press ahead with these advanced navigational capabilities without delay.

In the light of governmental targets for climate change mitigation, it is likely that long-term aviation traYcprojections will have to be scaled back. At some stage, we as a society will have to decide whether we arecontent to allow only the richest to travel by air, or whether a more equitable sharing of resources is possible.BBGA would like to see this equitability addressed now in terms of airport access and airspace design. Onceappropriate ratios are arrived at for all users to share scarce resources, they could all be scaled back asnecessary to meet environmental obligations.

Recommendation 1: Economic value (including induced value) should be at the heart of every UK aviationpolicy decision.

Recommendation 2: Congested UK airspace should be addressed in an integrated fashion with those of itsneighbours to enable rapid eYciency improvements.

Recommendation 3: Business & General Aviation should be given access rights to scarce resources whichcould then in turn be used as a model to protect low-cost carriers as Cap and Trade starts to impact theirbusiness model.

Recommendation 4: Airport capacity limits should be set with the primary aim of maximising the eYciencyof the Air TraYc System

2. Can safety be maintained as airspace is increasingly utilised? Is there a suitable interface between militaryand civilian arrangements for Air TraYc Control?

The UK can be justifiably proud of its ATC safety record, including the interface between civil andmilitary control. The forthcoming ATSOCAS changes will further improve the interface in areas outsideControlled Airspace, and the work of NATS and the CAA in this area is to be applauded.

However, in some areas it is apparent that the views of industry concerning safety are ahead of theauthorities; for example, the following are established BBGA positions on safety:

— The mandatory carriage of TCAS II / ACAS in congested airspace, regardless of aircraft weight.

— The mandatory requirement for two-crew operation of complex aircraft in congested airspace.

— The introduction of high-performance procedures to suit business jets arriving and departing atairports.

— The redesign of airspace to harmonise transition altitudes.

The adoption of the four points above would significantly enhance operational safety for all users ofcongested airspace, and should be addressed in a cross-functional manner involving industry and the variousagencies involved. We would encourage a systematic approach to safety in UK airspace, and an approachto apply six sigma methodologies across the functions involved in safety regulation, airspace design andaircraft operation.

Recommendation 5: A systematic, cross-functional approach to airspace safety should be undertaken, witha data-driven approach to improving safety statistics.

3. Is the current approach to planning and regulating the use of UK airspace adequate? Would an AirspaceMaster Plan covering the period of the White Paper be beneficial? Could a piecemeal approach to individualdevelopments necessitate additional redesigns subsequently?

The UK, taken individually, manages its airspace well. However, times are changing and a new approachis necessary for airspace management. Increasingly, the interface between UK airspace and those ofneighbouring Member States are the bottleneck for eYciency improvements, and it is here, as part of aEuroControl / SES initiative that the UK should focus its eVorts.

Recommendation 6: The United Kingdom should re-double its eVorts to drive up European AirspaceeYciency metrics through the SES programme as executed by EuroControl.

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4. How are the eVects and aircraft noise taken into account when changes are made to the use of airspace? Whoshould be consulted about such changes? How should the balance between conflicting interests be struck?

BBGA’s belief is that recent consultations have been well-run and fully inclusive. The care taken with therecent TC North consultation really underlines that point. However, it will become necessary, in order tomeet CO2 targets adopted by government, increasingly to override the ‘lifestyle’ views of consultees in theinterests of the greater good of reducing climate change. These unavoidable consequences of governmentpolicy relate to all aspects of human activity and not just aviation, and should be made clear to thepopulation as a whole without delay.

Recommendation 7: The UK government should make it clear to the electorate that “lifestyle” consultationresponses will be of progressively lower value in the decision process in order to speed up attainment ofenvironmental goals.

5. How does the management of airspace in the rest of Europe aVect flights into the UK? Is there an opportunityto integrate our plans for changes to airspace management more eVectively with those of other Europeancountries?

The design, planning and management of airspace in Europe needs to move towards increased levels ofintegration, including integration across national boundaries. The European Commission has made it clearthat it will not accept national “interests” to override the creation of eVective and widespread FunctionalAirspace Blocks (FAB’s) which are widely accepted to be the primary method of driving airspace utilisationeYciency up, and user costs down. Airspace users are impatient for these changes, and look to nationalgovernments to speed the long-awaited improvements to international airspace design.

6. What opportunities are there to apply new techniques and technologies to reduce wasteful flying on indirectroutes and excessive “stacking” while planes wait to land? How can the potential of any such opportunities bestbe realised? Could environmental benefits be gained as a result of such improvements?

Clearly there is a major role for technology to improve eYciency and reduce environmental impact ofaviation. The following areas of focus are the most important:

— The adoption and use of Required Time of Arrival (RTA) as a collaborative tool to sequencearriving traYc, especially long-haul flights.

— A seamless approach to flow management including all aspects of the journey, gate-to-gate andacross international borders.

— The application of user-defined trajectories for the enroute phase of flight.

7. In relation to the redesign of UK airspace, is the allocation of the roles and responsibilities of each of theinterested parties—Department for Transport, the CAA, airport operators, NATS, etc—appropriate andclearly understood? Are the structures of the parties appropriate for undertaking the roles that they should play?

BBGA’s belief is that there should be greater strategic cohesion between the domestic agencies listed. Forexample, no one is clearly tasked with safeguarding aerodromes with the result that many are facing threatsfrom development on or near the site of the aerodrome. There is no plan relating to the distribution ofaerodromes and how they should interface with airspace to make maximum use of available capacity, withthe result that we as a country will almost certainly not end up with an optimally designed airspaceinfrastructure. A more inclusive version of the White Paper analysing the entire inventory of the nation’sassets would be welcomed by this association.

As stated above, the future of an eYcient airspace infrastructure is increasingly going to have to lookoutside our national borders for solutions, and it is here that linkages need to be greatly improved.EuroControl should be required to coordinate national ATC agencies in such a way that the eYciency ofthe network as a whole is optimised.

8. Do airspace management considerations delay the planning processes in relation to airport developmentproposals? How will airspace management considerations be taken into account by the proposed newInfrastructure Planning Commission and the relevant National Policy Statements on airport planning?

Airspace management considerations seem to play at best a minor role in airport development proposals.The Infrastructure Planning Commission must be independent from Government, but set within a clearnational policy framework. This framework is largely absent outside the largest airfields and scheduledcarriers. Establishing a national spatial infrastructure plan that includes the needs of General and BusinessAviation will be key to establishing where major projects will be located and why. This must be linked intoairspace considerations, as aviation infrastructure consists of both land and air assets.

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The Farnborough airport situation is a case in point. Its owners have clearly invested millions of poundsinto the development of perhaps Europe’s finest and most modern Business Aviation terminal. And yet, itoperates under movement limitations dating back to its days as a military establishment and decided inisolation from any airspace considerations. Clearly, if the UK is serious about multi-modal sustainabletransportation policy, this is nonsensical. It is BBGA’s hope that the IPC can address this situation.

Recommendation 8: Government should speed the IPC and give it a clear brief including strategic principlesfor General Aviation and associated assets.

9. What could be the implications for smaller airfields, recreational flying and helicopters of changes toairspace management to enable safe and eYcient increases in capacity at the UK’s major airports? How shouldan appropriate balance between conflicting priorities be determined?

If traYc is to increase at major airfields, the requirement for controlled airspace will certainly increase.The impacts to recreational and other users can be mitigated to some extent by adopting new technologiesand procedures. Appropriate balance between conflicting priorities should be resolved through a value test.The majority of airline passengers are engaged in a leisure activity (vacation), comparable to the leisurepilots in GA. At some future stage we are going to have to invent a method of comparing the value anddesirability of these and other activities which compete for a share of finite resources, be they infrastructuralor actual. A low cost airline carrying passengers for one Euro each way does not contribute much to theNational economy beyond the value of the fuel they burn.

10. Will it be possible to recruit and train staV in order that airspace changes can be implemented in parallelwith additional airport capacity?

Yes.

11. Who should fund airspace changes? Is there likely to be enough funding to undertake the redesign requiredto bring about the necessary additional airspace capacity?

Recent events have clearly shown than anything is aVordable if there is suYcient will to do so.

To date, users have funded airspace development and design through user fees, and there is no reason toassume that this principle will change in a wholesale fashion. However, the returns to users in the form ofpromised savings and eYciency gains have often been overstated at best or non-existent at worst. This needsto be addressed so that the agency/ies making commitments to eYciency improvements have more tangiblecommitment to a successful outcome. This could be in the form of a charging cap imposed in a similarfashion to rail operators which fail to meet standards agreed with their regulator.

At the light end of the operational spectrum, the Australian experience with ADS-B is worthy of study.In that case, the Australian government decided to share some of the cost-savings resulting from thedecommissioning of radar stations to fund the adoption of Mode S ADS-B systems into light aircraft, whichoperationally would not have benefitted from the adoption of ADS-B, thus removing the last obstacle tothe decommissioning of the radars and allowing the consequent cost-savings. This seems to be a pragmaticsolution to a cost-benefit imbalance, which is worthy of imitation.

Recommendation 9: The UK should adopt a clearer, risk-sharing, approach to airspace eYciencyinitiatives, with the UK provider bearing financial risk in the event that promised eYciencies do not materialisedespite investment by users and the agencies concerned.

Thank you for this opportunity to provide input into the future of Airspace in the UK. We very muchhope that our response above indicates the level of thought that the BBGA has given to the topic, and lookforward to engaging in further dialogue in due course.

March 2009

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