Gatwick ADNID SID trial - Impact and Consultation

T Henderson made this Freedom of Information request to Civil Aviation Authority

This request has been closed to new correspondence from the public body. Contact us if you think it ought be re-opened.

Waiting for an internal review by Civil Aviation Authority of their handling of this request.

Dear Civil Aviation Authority,

Under the Environmental Information Regulations, please can you send me information(including emails) sent and received by the Civil Aviation Authority in connection with the impact of change to the environment expected as a result of the recently-commenced trial of the ADNID 1X SID at Gatwick and the degree of proportionate consultation determined by the CAA that was deemed necessary before granting approval for the trial.

Yours faithfully,

Tim Henderson

FOI Requests, Civil Aviation Authority

Corporate Centre
Information Management

Dear Mr Henderson

The CAA acknowledges receipt of your Information request.

If your requirements are unclear, or the information is held by another public body, we will contact you in the next five working days. Otherwise the information we are able to release, under the Environmental Information Regulations 2004, will be assembled and made available to you within 20 working days from date of receipt. If an exemption applies to any of the information requested an explanation will be provided.

Should you wish to discuss any aspect of this request, I can be contacted on:
01293 768512. Please quote reference E0001862.

Yours sincerely

Rick Chatfield
Information Rights and Enquiries Officer

show quoted sections

Chatfield Rick, Civil Aviation Authority

1 Attachment

Dear Mr Henderson

 

Please find attached:

 

·         CAA response to your Environmental Information Regulations
request E0001862

 

Yours Sincerely

 

 

Rick Chatfield

Information Rights and Enquiries Officer

External Information Services

Civil Aviation Authority

 

Tel: +44(0)1293 768512

 

[1]www.caa.co.uk

Follow us on Twitter: [2]@UK_CAA

 

Please consider the environment. Think before printing this email.

 

 

show quoted sections

References

Visible links
1. http://www.caa.co.uk/
2. http://twitter.com/UK_CAA

Dear Civil Aviation Authority,

Thank you for the response to my request.

Unfortunately, in referring me to the correspondence on F0001841 it has not dealt with the substantial items of my query :

information on the expected impacts on the environment of the trial

the degree of proportionate consultation deemed necessary by the CAA prior to approval

rather than the F0001841 topics of the purpose and duration of the trials,the criteria for CAA intervention and the complaints process if CAA are not adequately fulfilling their duties.

I note that S Lindsey, Head of Airspace approved the trial on 31st January 2014 and referred to the decision being based on the review of information provided by the project, mainly the Route Spacing Assurance Document (4987/SAF/18 Issue 1). Would this
have included the environmental impact assessment undertaken ? Or would that have been in the other information provided ?

I note references to waymark positioning being in part determined by impact on local communities but have seen no documentation or evidence to show how this was carried out prior to approval.

Please could I repeat my request for the information held by the CAA on the impact assessment prior to approval or a statement that no such information was prepared/provided.

Similarly I could find no information released that the CAA determination of the consultation appropriate for the trial would be the sole mention of the trial at the GATCOM meeting of 30th January.

Yours faithfully,

T Henderson

T Henderson left an annotation ()

Sent to mark.stevens@caa.co.uk on 7th April :

I have received the response to my request

https://www.whatdotheyknow.com/request/2...

and this indicates that if I am not satisfied with how the CAA has dealt with the request,I should write to yourself.

I have posted the following letter at

https://www.whatdotheyknow.com/request/g...

and am copying it here :

From: T Henderson

7 April 2014
Dear Civil Aviation Authority,

Thank you for the response to my request.

Unfortunately, in referring me to the correspondence on F0001841 it
has not dealt with the substantial items of my query :

information on the expected impacts on the environment of the trial

the degree of proportionate consultation deemed necessary by the
CAA prior to approval

rather than the F0001841 topics of the purpose and duration of the
trials,the criteria for CAA intervention and the complaints process
if CAA are not adequately fulfilling their duties.

I note that S Lindsey, Head of Airspace approved the trial on 31st
January 2014 and referred to the decision being based on the review
of information provided by the project, mainly the Route Spacing
Assurance Document (4987/SAF/18 Issue 1). Would this
have included the environmental impact assessment undertaken ? Or
would that have been in the other information provided ?

I note references to waymark positioning being in part determined
by impact on local communities but have seen no documentation or
evidence to show how this was carried out prior to approval.

Please could I repeat my request for the information held by the
CAA on the impact assessment prior to approval or a statement that
no such information was prepared/provided.

Similarly I could find no information released that the CAA
determination of the consultation appropriate for the trial would
be the sole mention of the trial at the GATCOM meeting of 30th
January.

Yours faithfully,

T Henderson
--------------------------------------------------------------------------------------
Response on 8th April :

Dear Mr Henderson

Thank you for your email.

I suggest that we speak to the relevant experts and see if there is any other relevant recorded information or if we can provide a bit more explanation – although I have not been closely involved in this request, I believe it is more likely to be the latter rather than the former – rather than carrying out a full internal review at this stage.

I would hope that we can get back to you in the next few days.

Yours sincerely

Mark Stevens

External Response Manager

External Information Services

Civil Aviation Authority
--------------------------------------------------------------------------------------
Reply to CAA 8th April

Thanks for the prompt reply.

I would agree that it doesn't seem appropriate to launch a full internal review at this stage.

I note from the sources below that Andy Taylor of NATS has made comments on the relative impacts of routing alternatives and I would presume that this information would have been provided to CAA in their oversight of the trial process in accordance with the Air Navigation Guidance to the CAA Section 9.10

.... the likely impact of the proposed change on the environment should be considered by the sponsor prior to implementation and this information used to help the CAA to determine whether a proportionate consultation is required.

(My bold emphasis is added in the extracts.)

Regards,

Tim Henderson

http://www2.westsussex.gov.uk/ds/cttee/g...

GATCOM STEERING GROUP – MATTERS CONSIDERED
REPORT BY CHAIRMAN
This paper summarises the matters considered by the GATCOM Steering Group at its meeting on 20 March 2014.

.....
2. ADNID DEPARTURES SEPARATION TRIAL - UPDATE
2.1 GAL updated the Steering Group on the operational departures separation trial. The purpose of the trial is to gather data to help develop national standards for improved efficiency for runway use and to establish whether it is operationally feasible to improve time separation between flights off Gatwick’s runway using Performance Based Navigation technology. The trial route is to to test the flyability of a smaller angle of divergence from the centre line of the runway allowing increased use of the runway and improved resilience. GAL advised that the trial route had been designed to avoid the overflight of built up areas as far as practicable. However the use of the trial route has generated a significant number of complaints from the Warnham, Kingsfold and Slinfold areas. The trial is due to finish mid-August 2014.
2.2 The Secretariat has also received a number of complaints. Members of the Steering Group and GATCOM’s members appointed to serve on the Noise and Track Monitoring Advisory Group (NATMAG) have been informed of the concerns raised by the residents including those of Warnham Parish Council.
2.3 Members were reminded of the Government’s policy of limiting and where possible reducing the number of people significantly affected by aircraft noise and that in minimising the number of people over-flown at low levels the Government accepts that, in general, the balance of social and environmental advantage lies in concentrating aircraft taking off from airports along the fewest possible number of specified routes avoiding densely populated areas as far as possible. It was explained that the trial route means that several more villages were now experiencing much less overflight. The Government’s policy of concentrating aircraft tracks gives cause to a number of significant local issues where the impact on those living under flight paths was greatest.
2.4 The processes involved in making changes to noise preferential routes (NPRs) were also
discussed. The DfT confirmed that any changes to existing or new NPRs would require the approval
of the Secretary of State for Transport. It was pointed out that aircraft were generally higher than
4000ft over Warnham/Slinfold areas so they would not necessarily fall within the NPR (above 4000ft
aircraft are vectored off the NPR) if it was decided at a future date to make such a route permanent.
2.5 The Steering Group felt that the timing of the trial was most unfortunate given the recent
close of the London Airspace Consultation and the options being considered for a second runway
which has given rise to much anxiety locally about possible changes for the future. It was
emphasised that people had purchased properties having researched the position of flight paths and
had paid a premium to live in areas with very little overflight. It was important that NATS/GAL
seriously considered the impacts on the ground as well as the operational and safety benefits. The
location of the route and the angle of divergence was discussed and GAL/NATS was asked to give
consideration to slightly changing the angle of divergence or the point of divergence further west
along the centre line to route traffic over woodland and farmland......

Noise and Track Monitoring Advisory Group 27 February 2014 Gatwick Airport

http://www2.westsussex.gov.uk/ds/cttee/g...

11 AOB
ADNID Trial
1. The Group was provided with Noise and Track keeping density/height plots comparing pre trial and in trial overflight data.
2. Liz Kitchen told the group that Warnham should have been told of the intention to commence this trial. Certain people have lived there up to 40 years and suddenly are experiencing more aircraft noise.
3. In response to a comment that there had been no consultation, Ros Howell stated that, whilst recognising the trial is a different matter, the ADNID route is within the departure (and arrival) route swathe of the recent London Airspace Management Programme (LAMP) consultation and, as such, Warnham residents have been consulted on their opinions of this type of route passing overhead although not in such an immediate timeframe. Andy Taylor advised that this trial route is not flown during the night time period as it temporarily replaces the BOGNA and HARDY SID routes, and when this route is not used traffic reverts to the existing departure routes. Matthew Balfour commented that this is how the future will look and people need to be aware. John Byng said the residents of Warnham were not told despite Ros Howell’s explanation and furthermore GAL did not do so due to the risk of initiating complaints. John Byng went on to say that at a recent GATCOM he made the suggestion that the Parish Council should be notified but GAL did not do so.
4. Andy Taylor advised the Group that the purpose of the trial is to prove a new separation standard as the most recent CAA data available dates from the 1980s (based upon upper air routes over Maastrict) and is not representative of today’s modern aircraft or lower altitudes. It has been agreed with the CAA that a 6 month trial length is required to obtain sufficient data.
5. Mark McLaren provided the group with an overview of his role at the CAA which includes oversight of such trials. He advised the group that this trial forms part of the mandatory Future Airspace Strategy (FAS). He confirmed that the ADNID Trial complies with the Government policy of concentration rather than dispersal and has a purpose to inform FAS and has a defined start and end date whereas the permanent change process of LAMP Phase I is continuing. Should this trial be adopted as a permanent airspace change proposal, then CAP725 consultation rules would apply.
6. Ros Howell explained that the London Airspace Consultation (LAMP Phase I) stated no second consultation on routes will take place once they have been decided. John Byng mentioned this is exactly what is causing the issues and Matthew Balfour responded by saying there will be partial consultation after LAMP Phase I and this is better than nothing. Ros Howell reflected on Matthew Balfour’s previous statement regarding ‘this is what the future will look like’ and is an example of where the route is moved benefitting many people (Andy Taylor had advised that four villages previously overflown were now avoided) while a smaller number could be more affected. However, this is in line with DfT policy.
7. Ros Howell also commented that recent increase in complaints could potentially represent a small but vocal minority versus a silent majority.
8. Liz Kitchen advised that country dwellers have different expectations due to quieter residual noise. Alan Jones mentioned that there are lots of workstreams and consultations ongoing however there will be winners and losers plus respite for others. GAL are going to be plagued with complaints however people want to fly and these people do fly.
9. Peter Long questioned on what overflight actually is because if somebody can see aircraft from their garden they will consider this overflight even if the aircraft are technically not directly overhead. It was then suggested that as a noise monitor is in location in Rusper and is affected by this trial it would be prudent to supply the Gatwick Noise Monitoring Group with pre and post trial data for review. ACTION 05/2014
10. Andy Taylor clarified that this is not an environmental trial but a technical one to allow a 20 degree split away from another SID route that also ensures separation from the “WILLO” hold therefore it is not possible to relocate it elsewhere.
11. John Byng told the Group that people in Warnham are complaining because they bought their properties knowing where the flight paths are and now they have moved. Furthermore aircraft are climbing in a concentrated manner at 4000 feet. John Byng has been instructed to ask that the trial be terminated once sufficient technical data is sourced. Tom Denton stated that under FAS/LAMP some people would be better off, a smaller number may be worse off and some will see little change. Ros Howell referred previous and consistent responses from GATCOM to the previous consultations on CAA Strategy, CAA Future Airspace Policy, DfT Aviation Policy Framework, Night Flying Restrictions, and the London Airspace Consultation that pointed out that the increased use of PRNAV and the policy of concentration rather than dispersion will benefit the majority but that, increasingly, a minority will suffer to a greater degree, and that something needs to be done to address this issue. John Byng responded does the suffering of the minority ever outweigh the benefit of the majority?

----------------------------------------------------------------------------------------------------------------
From CAA 9th April

Dear Mr Henderson

I have just discussed this with my airspace regulation colleagues.

We have received a number of enquiries and complaints about this trial, and as a result they are currently working on producing a full explanation of how the CAA arrived at the decision to approve the trial and how we intend to monitor it from now on. From what I understand, this should answer your questions.

They anticipate that this should be available sometime next week and I will be able to send this to you once it has been finalised.

Regards

Mark

-----------------------------------------------------------------------------------------------------------------
To CAA chasing up response on 22nd April

Dear Mr Stevens

Is there an update for the issue of the full explanation ?

It didn't appear that you were able to issue it last week.

Regards,

Tim Henderson
----------------------------------------------------------------------------------------------------------------
From CAA 22nd April
Dear Mr Henderson

I have asked for an update from the department concerned and will let you know as soon as I know more.

Regards

Mark
------------------------------------------------------------------------------------------------------------------
From CAA 24th April
Dear Mr Henderson
I am advised that this has not been finalised yet, but should be very soon. I will update you as soon as I know more.
Regards
Mark
--------------------------------------------------------------------------------------------------------------------

T Henderson left an annotation ()

Received from CAA 1st May 2014 :

Dear Mr Henderson

Apologies for the delay, but please find attached the document referred to and the outline of the Airspace Change Process mentioned within it.

Yours sincerely

Mark Stevens

External Response Manager

External Information Services

Civil Aviation Authority

----------------------------------------------------------------------------------------------------------------------
ADNID TRIAL – CAA POSITION

The ADNID trial, sponsored by NATS/Gatwick Airport Limited (GAL), began on 17 February 2014 for a 6-month period. We have since received a large number of queries and complaints concerning this trial. In response to the concerns raised, this letter seeks to explain the background to the ADNID trial, its approval process and our position concerning its continued operation.

The ADNID trial is one of a number to help develop the UK’s Future Airspace Strategy. The basic structure of the UK’s airspace was developed over forty years ago. Since then there have been huge changes, including a hundred-fold increase in demand for aviation. Throughout Europe there is a move to simplify and harmonise the way airspace and air traffic control is used, through the Single European Sky programme . In the UK and Ireland we are meeting those and other issues through the Future Airspace Strategy.

One of the key enablers of the Future Airspace Strategy is the use of new technology that replaces obsolescent ground-based navigation beacons with modern satellite based navigation systems. The implementation of this new technology will not only contribute to a more efficient use of the UK’s limited airspace resource but, will also deliver environmental benefits especially in reduced fuel consumption and less CO2 emissions. Conventional procedures are less precise and provide less opportunity to realise these benefits. The new technology is likely to be mandated across Europe within the next decade.

The majority of commercial air transport aircraft are already equipped to make use of the technology. The conversion of operational procedures to match the airborne capability requires the creation of safety standards that will apply to both to the design of airspace procedures and to the separation distance between adjacent air routes. These new standards can only be established where trials have been used to confirm the track-keeping ability of aircraft. Whilst simulation can be used to a certain extent, only when these procedures are actually flown, allowing operational and weather factors to be assessed, can the required safety assurance for the new procedures be established .

Further trials are planned for London Heathrow Airport. Trials are progressed in accordance with the attached guidance and the CAA Case Officer nominated for each trial is required to assure him/herself that the parts of the guidance appropriate to a trial have been complied with.

The length of the ADNID trial was required for up to 6 months in order to gather sufficient data and to assess the safety of the procedures used. Wind direction and air traffic controller intervention can reduce the amount of data collected, in an unpredictable manner. ADNID departures can only take place when the wind has a westerly component, due to the requirement for aircraft to take-off and land into wind. Wind direction and air traffic controller decisions will vary and there can be no realistic expectation that a guaranteed number of data points will be generated during any given time period. Given that uncertainty, it is difficult to predict how long the trial will need to continue in order to fulfil its aims. We are closely monitoring the ADNID trial to ensure that it is curtailed as soon as sufficient data has been gathered. In any event, the trial will cease after 6 months.

Should NATS/GAL wish to create a Standard Instrument Departure route (SID) using the profile of the ADNID trial, that proposal would only be established in accordance with the airspace change process, a summary of which is attached to this letter and includes a more wide ranging and formal consultation requirement. We would not approve extension of the ADNID trial during the airspace change process and the airspace will revert to its original structure at the end of the ADNID trial period.

We approved the ADNID trial based on discussions between our nominated CAA Case Officer and representatives of NATS/GAL. From those discussions, we considered that the trial route had been designed to avoid the overflight of population to the greatest possible extent given the aims and parameters of the trial.

Numerous trials have been approved by us, based on the need to fulfil a specific aim and are normally short-term. The airspace change process provides safeguards to ensure that trials do not become permanent changes, without the statutory requirements associated with consultation being fulfilled. The Secretary of State’s Guidance to the CAA Relating to the Discharge of its Air Navigation Functions, requires us to consider whether consultation for a trial is appropriate and if it is, the nature and extent of the exercise in relation to the given trial. In certain cases, there may be no requirement to consult over a trial. In this particular case, given the design of the trial route, we considered that the engagement of the sponsors with the Gatwick Airport Consultative Committee (GATCOM) was adequate, noting that GATCOM had acted successfully as a vehicle for engagement during the proposals to establish precision based navigation departure routes in late 2013. A formal airspace change has a much more rigorous consultation requirement.

A number of correspondents have stated that they consider the ADNID Trial to be a temporary airspace change and have suggested that it should therefore, be limited to 90 days. It is necessary to clarify the characteristics of these 2 separate activities:
A temporary airspace change constitutes the CAA’s response to a specific operational activity beyond our control or the air navigation service provider involved (such as NATS) requires a change to airspace arrangements to accommodate that activity safely. An example of this would be the London 2012 Olympics where due to the influx of traffic and the security implications of that event, significant changes had to be made to the airspace structures and procedures associated within the South East UK to ensure that demand could be accommodated. Consultation was undertaken with aviation organisations to ensure that procedures were workable but, there was no wider public consultation as the change was a temporary measure. The application of a temporary airspace change is detailed in Civil Aviation Publications .
A trial aims to prove provide evidence about the characteristics of a particular mode of operations. It is not a response to a particular operational requirement or event, but must have start and end dates and have specific aims. An airspace trial is not governed by CAP 724/725 but, in the event that a trial sponsor wished to make a trial permanent, then the Airspace Change Process detailed in CAP 724/725 would apply .

We are closely monitoring the progress of the trial to ensure that it ceases as soon as the required quality and quantity of data has been collected. The trial route will be withdrawn after 6 months regardless and the airspace will revert to its original structure. Should the trial sponsor wish to introduce the ADNID route on a permanent basis, be assured that the airspace change process, which includes a wide ranging and formal consultation requirement, would apply; the route would not be left in place pending a decision on such an application.

Footnotes :

1) http://ec.europa.eu/transport/modes/air/...

2) The purpose of the ADNID trial is to:
a. Collect data to inform a case for a reduced angle between aircraft on departure whilst maintaining safety and making the most efficient use of a particular runway

b. Gather radar data to confirm greater the precision of track keeping, thereby allowing a reduction in the lateral distance between adjacent air routes.

3) (CAP 724 (The Airspace Charter) and CAP 725 (CAA Guidance on the Application of the Airspace Change Process)

4) The criteria for designing safe trials are detailed in CAP 670 (Air Traffic Service Safety Requirements)
-----------------------------------------------------------------------------------------------------------------------

Dear Civil Aviation Authority,

Please pass this on to the person who conducts Freedom of Information reviews.

I am writing to request an internal review of Civil Aviation Authority's handling of my FOI request 'Gatwick ADNID SID trial - Impact and Consultation'.

Thank you for the response from Mark Stevens on 1st May with the letter which purported to " explain the approval process" and said that "trials are progressed in accordance with the attached guidance." Unfortunately, the only attached guidance appeared to be a summary of the full permanent seven stage airspace change process. Clearly the current trial was not progressed in accordance with this. It was mentioned that the CAA case Officer was required to assure himself that the parts of the guidance appropriate to a trial have been complied with - but it is still not clear what guidance is being referred to.

Later, it notes that "we approved the trial based on discussions between the nominated Case Officer" and the trial sponsors. "From discussions, we considered that the trial route had been designed to avoid the overflight of population to the greatest possible extent given the aims and parameters of the trial."

Could I repeat that my request for the impact assessment of the trial on the environment provided by the trial sponsors remains unmet. I note that the rationale of waypoint positioning of KKW12 mentions that in addition to providing separation for the WILLO hold it was positioned considering the impact on local communities - but this does not seem to provide evidence to support the contention that the design avoids population overflight to the greatest possible extent. What other options were considered ? Why were no intermediate waypoints in the long gap between KKW2 and KKW12 used ?

The emails from early October mention calculations, drawings and compliance check folders as components of Version 1.3 of the Gatwick BOGNA trial package. Would perhaps earlier versions include consideration of the other environmental options and a documented rationale for the route that was implemented ? Or is full information on this recorded in the minutes of the discussion meetings between CAA and the sponsors ?

The Guidance to the CAA on Environmental Objectives Relating to Air Navigation has a section on trials:

.....Consultation arrangements for temporary airspace arrangements and operational airspace trials

9.10 Due to the short term nature of temporary airspace changes and airspace trials, it will usually not be necessary or appropriate for the airspace change sponsor to consult on their proposals or to undertake the airspace change approval process.

However, the likely impact of the proposed change on the environment should be considered by the sponsor prior to implementation and this information used to help the CAA to determine whether a proportionate consultation is required.......

Accordingly I would like to confirm my request that an internal review is carried out into the failure to provide the information requested.

A full history of my FOI request and all correspondence is available on the Internet at this address: https://www.whatdotheyknow.com/request/g...

Yours faithfully,

T Henderson

FOI Requests, Civil Aviation Authority

Dear Mr Henderson

Thank you for your email.

As per our internal review procedure, we will ask a senior manager to review the original decision and they will be in touch shortly.

Yours Sincerely

Rick Chatfield
Information Rights and Enquiries Officer
External Information Services
Civil Aviation Authority

Tel: +44(0)1293 768512

www.caa.co.uk
Follow us on Twitter: @UK_CAA

Please consider the environment. Think before printing this email.

show quoted sections

FOI Requests, Civil Aviation Authority

Dear Mr Henderson

Thank you for your email.

As per our internal review procedure, we will ask a senior manager to review the original decision and they will be in touch shortly.

Yours Sincerely

Rick Chatfield
Information Rights and Enquiries Officer External Information Services Civil Aviation Authority

Tel: +44(0)1293 768512

www.caa.co.uk
Follow us on Twitter: @UK_CAA

Please consider the environment. Think before printing this email.

show quoted sections