Policy – The UK CAA in CAP 1616 Airspace Change (2018) outline procedures that must be followed by airports when introducing airspace. This 7-stage process makes specific requirements for stakeholder engagement and CAA approval at pre-determined gateway points in the decision-making process. To date as a result of COVID-19 most airports have paused the implementation of this airspace change process at Stage 1B, consultation on design principles. Thus, it is on this stage that this case study focuses.
Airport responses – the review of 12 airports’ engagement with the ‘design principles’ engagement step 1B of the CAA process, focused first on the processes of stakeholder engagement and then their outcomes.
The review of the engagement processes revealed that:
- Airports had made clear attempts to address the CAA’s engagement priorities involving a wide range of stakeholders in different modes of engagement, with relevant communities identified as those within the geographic footprint of aircraft operating under 7000ft to and from the airport.
- The consultation described within the various airport reports tended to focus on questions around noise priorities and noise versus emissions, as well as technical and operational issues.
- The main methods adopted were focus groups, workshops and online questionnaires, supplemented with emails, dedicated websites and leaflets
- Differences in the responses of those attending focus groups and those using online feedback methods was identified in some cases
Review of the emergent draft Design Principles demonstrated the priorities addressed the following issues:
- Safety – targeting changes to reduce risks and ensure compliance with industry standards and regulations
- Airspace users – these address the impact of changes on other airspace users, seeking to minimise impacts
- Technology – emphasis is placed on the utilisation of the latest navigational technology to deliver operational and environmental benefits
- Policy – relating to delivering on existing UK aviation policy and associated guidance
- Capacity/continuity – development of airspace that provides continuity of services and maximises utilisation of existing and planned new infrastructure
- Emissions – relating to the control of climate change and local air quality emissions
- Noise – those DPs designed to address noise effects
The wording of all noise-related DPs implies that these are discretionary and should therefore be achieved where ‘possible’/‘practicable’. Most airports commit to minimise the overall impact/effects of noise exposure and/or minimise the number of people affected.
Summary of UK Airport Noise-Related Airspace Change Design Principles
Whilst not referring to minimising impacts nor people exposed to noise Aberdeen Airport’s DPs do refer to ‘investigating steeper approaches… to reduce noise footprint’ and also ‘minimise changes to tracks’, with the latter by implication minimising populations newly overflown.
Significantly, commitments seeking to minimise the total number of people overflown/affected by noise and to minimise the population newly overflown may conflict with the design principles intended to share noise/routes to allow for more equity and/or respite. The challenge of trading-off between DPs at the airspace change proposal stage would appear to be all the more difficult given the absence of any prioritisation between DPs evident in many submissions. Further, addressing these challenges would seem to require some agreement on how to capture performance against specific noise-related DPs using metrics that describe operations and their noise consequences (to allow the relative merits of different options to be illustrated and informed decisions made); again engagement with stakeholders over DPs appears to have completely omitted to consider this issue.
Amenity group member focus groups revealed a consistent view that PBN is undesirable for communities. This was expressed by all participants, with the perception being largely driven by a general agreement that concentration would be catastrophic for any communities below concentrated flight paths. Participants also expressed concern about PBN’s potential application as a method to provide noise respite by flying different and alternating concentrated flight paths. It was suggested that multiple alternating and low-capacity flight paths would themselves fill up over time, resulting in multiple heavily concentrated flight paths rather than providing respite.
In short, there was a strong sense that the participants did not trust the aviation industry to implement PBN effectively, believing that environmental externalities are a secondary concern to growth, using the industry’s importance to the economy and society as a means to justify such growth, whatever the local impacts.
Regarding communication, participants demonstrated some empathy for the industry in its efforts to convey complex information in simple ways that were comprehensible to non-experts. However, there was also a sense of frustration as to the industry’s inability to do so effectively.
Overall, noise sharing is preferred by those who are exposed to noise, although this runs counter to government policy to avoid newly overflying people. It appears then that there is an imperative for policy to be revisited as part of the processes of airspace modernisation.
Heathrow experiences - from implementing the CAA’s airspace change process to date revealed the following issues:
- Overly long consultation processes (exacerbated by COVID) – whilst early engagement is recognised as important there is a tension between the desire to engage early over key principles but a lack of specificity, and iterative approaches make the process arduous for all involved. Thus, there is a need for careful management of the whole process if stakeholders are to remain actively engaged in informing outcomes.
- Design Principles conversations demand a ‘context-free’ examination of issues which can be a challenge when participants are often keen to understand what it means for them. However, as soon as lines are drawn on a map a ‘not over my back yard’ attitude can dominate, inhibiting discussions that can support consensus building.
- Prioritisation/ranking of design principles was regarded as essential if this stage in the CAA process is to facilitate future stages where the merits of specific airspace change options have to be illustrated, discussed and decided upon.
- Focus groups were seen as a particularly useful technique in facilitating the open-end discussion needed to explore principles as opposed to deciding between specific proposals. They were associated with more nuanced understanding of issues of concern and the building of empathy.
- Noise sharing and respite are common design principles that may require further examination of what it is that the public views as important to help guide the determination of success factors. It would appear that there needs to be a better understanding of what people expect sharing and respite to bring.