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Will new consultation rules for airspace changes lead to long delays?

After shutting NHS maternity units or proposing new housing on Green Belt, just about the most controversial public consultations are those affecting airspace changes around our airports.

What few people, and even local councils have realised, is that those living within audible distance of an UK airport will soon be consulted about changes to the noise footprint of arriving or departing aircraft. Technology changes makes some adjustments inevitable and noise-reduction campaigners are bound to seize upon every opportunity to press their case.

For airports there is a particular challenge. New rules brought in by the Civil Aviation Authority (CAA) in January oblige them to observe onerous obligations for public engagement and consultation. Indeed, long before they can launch a consultation, they have to go through hoops to justify the need for change. For example:

 

  • They have to establish precisely what airspace changes need to be considered. For every route arriving or departing an UK airport, there is a formally approved ‘procedure’. There are hundreds of routes, many of which may need to be amended to cope with the new technology.

 

  • Airports must make a ‘prima facie’ case for initiating the new CAA change process known as CAP 1616. This is a 218-page volume of extraordinary complexity, full of demanding requirements, where failure to observe the rules will oblige the airport to resubmit its change proposals causing delay and extra costs.

 

  • They must involve and engage stakeholders in agreeing the design principles that will govern their development of options that might go to a public consultation.

 

  • They must evidence this involvement in a submission to the CAA in order to pass the ‘Define’ Gateway, enabling them to proceed to options development itself.

 

  • Once the options have been developed, stakeholders must understand the process that took place before airports can seek approval to hold a public consultation, by successfully passing the ‘Develop & Assess’ Gateway

 

Only when these steps have been successfully negotiated will airports be able to prepare and formally launch a public consultation – and even then, their consultation plans will need to be scrutinised by the CAA and pass the ‘Consult’ Gateway.

 If all this sounds tortuous, it is, of course, logical and necessary if communities are to have confidence in the integrity of the process. The worry is that so much depends upon the capacity of the CAA to process multiple airspace change proposals at any one time. A little like our airport runways, there may be congestion on the taxi-ways as several initiatives queue up for take-off. Being at the back of this particular queue may cause immense problems for airports. Once communities get wind of potential changes, they will become anxious and press to move quickly by reducing the period of uncertainty to minimum.

Airports will need to be really smart in moving rapidly through the preliminary steps described earlier. Pre-consultation stakeholder engagement is nothing new for infrastructure planning or the NHS, but the CAA’s new rules will oblige airport operators with less experience of this difficult area to learn-by-doing.

The Institute has already provided expertise through controversial airspace change and is now working with Jim Walker to help airports through this labyrinthine process.

On 24 April 2018 in Birmingham, we are holding a specialist event:

Forthcoming Changes in UK Airspace Meeting the public engagement challenges of the Civil Aviation Authority CAP 1616 process – at which these issues and their implications will be fully discussed.

View the agenda and book here.

At this event, we will publish the Institute’s own Briefing Paper: Public Engagement Aspects of Airspace Change in the UK. It goes into greater detail about the challenges posed by the CAP 1616 process and recommends Best Practice activities that should be considered by airport operators who wish to find a way to the front of the queue! Advance copies of this paper are available upon request from the Institute. Please call Becky on 01767 318350.

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