Exeter airspace grab

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Viv Fouracre
Viv Fouracre's picture
Exeter airspace grab

For those who are not on the Telegram groups and are not aware, this is a proposal from Exeter Airport to extend their airspace. It is a considerable extension and will impact on several of our sites. Tom Hardie of the BHPA is already aware of this and the local clubs have only just been asked for their input. I will put something together on the Condors behalf later this week and will post updates here as and when I have any more information or when there is an opportunity for any members to get involved.  If you want to read the whole document it can be downloaded here: https://www.exeter-airport.co.uk/acp-consultation/

Simon Vacher
Respones to Viv Fouracre

Dear All,

I have compiled a few responses from members about the Exeter Airspace proposal and will be forwarding these to Viv today along with my own annotated notes which I will also post here. If anyone else has further comments, please send them to Viv before Sunday. Viv will then send these to Tom Hardie at the BHPA who will then advise to as the next steps.

 

Many thanks,

 

Simon

Viv Fouracre
Viv Fouracre's picture
Airspace update

Attached docs sent to Tom Hardie at the BHPA.

John Wreford
John Wreford's picture
Exeter airspace grab

Viv, thanks for all your hard work on this. John W

Nick Jenkins
Nick Jenkins's picture
Airspace

Yes, thanks Viv for all your hard work on this problem,

Antony Davie
Air Space Exeter

Thanks Viv for your efforts to preserve our sites which will be affected, ie Easthill, Bucknowle,Farway,Branscombe,Beerhead and Sandybay. This last site being in the proposed CTR also. At the Budligh salterton end, which is crutial for landing option on beach.

Simon Murphy
Simon Murphy's picture
Last day

Today is the final day for responding to the Exeter proposals.  Whilst it seems there are hopes the whole thing will be delayed due to technical errors in the way it has been handled, I feel it is best to lodge as many responses as possible, and thus have emailed the following:-

"

Dear Sirs,

 

As a local hang glider and paraglider pilot operating in the area for over 40 years, I’ve had a look at the Exeter Airport Airspace Change Proposal document and feel that, if implemented, they would severely restrict my flying.

 

In my 40+ years flying in this area I am only aware of one airmiss involving a free flyer. This was the subject of a JAWG investigation, at which the BHPA representative told me that the pilot of the light aircraft involved was strongly criticised as having been “sent up in order to fly close to a hang glider at East Hill”!

 

The following are points I would make about the Changes Proposal document:

 

1) In the Executive Summary it is stated that current operations are safe. This indicates that the whole plan is unecessary.

 

2) It is stated that there have been incidents that “could have potentially led to a degradation of safety margins”, but that strongly infers that they didn’t, in which case they can be ignored.

 

3) it is suggested there is an “event” roughly every five days, which doesn’t seem too onerous, given the facilities at the disposal of ATC. They then repeat that current operations are safe, once agin undermining the need for such drastic changes.

 

4) In the section on the ACP it is said that the changes will “enhance efficiency”. Since current operations are declared safe, it seems they are saying that it is their own efficiency that will be enhanced. At what cost will this be implemented to those other “aviation stakeholders” who are mentioned, but not identified?

 

5) In Regulatory Background they state that the aim is to meet the requirements of all airspace users. In fact, many local airspace users have been totally overlooked.

 

6) They are arrogantly assuming that it is unlikely any changes will be needed. (1.7)

 

7) Given the assertion that current operations are safe, a quick glance at the proposed changes on the map provided seems to suggest that this is the proverbial sledgehammer to crack a nut.

 

8) The table showing projected use of the airport suggests a reduction in operations until 2018.

 

9) Forecasts for the next five years suggest a possible increase in activity estimated at being 10%. Given the uncertainty surrounding Brexit negotiations, these can be taken with a pinch of salt.

 

10) It is stated (3.2.)that they have been proactive in engaging with local airspace users. I have been involved in Free Flight in this area for over 40 years as a member and officer of three different clubs and groups, and cannot recall a single occasion on which any of these groups have ever been contacted by Exeter Airport. On this occasion we only heard about the proposed changes after being tipped-off by a pilot working at Westlands, and even they had not been contacted directly! This statement is thus shown to be absolutely untrue, and contact with local airspace users is at best woefully inadequate. They don’t seem to be aware of what is going on in their back garden.

 

11) Even though the airport have made no attempt to discuss matters with us, they suggest that they have had negotiations with the local gliding and light aviation centres. Such arrangements will not be workable for us, since our lower performance and lack of a power source to drive instruments and radios means that we are not able to take advantage of any agreements which may eventually be reached with other flying groups.

 

12) The stated aim of the proposed design (4.1) is to minimise disruption to local aerodromes and GA activities. Unfortunately, these proposals would greatly restrict our flying at Smeatharpe. Our relatively low performance demands that we utilise thermals as close to cloudbase as the rules permit, and to prevent us climbing out above 3000 feet would render our flying site almost useless for its main purpose - cross-country and thermal flying.

 

13) Under (4.3) VFR Flights and VRP and (5.1) Overview of potential effects on Airspace Users, the airport infers that they will be able to accommodate most users without difficulty. None of this applies to our mode of flying. We cannot contact the airport, we cannot hold a given course, and we cannot tell where our next source of lift will be found. The Airport clearly intends to ignore us completely, while dishonestly pretending that we have been contacted and involved in discussions.

 

14) In (5.4. and 5.4.3) Effect on Local GA Operators, the airport seem to be willing to accommodate the gliding fraternity with a Glider Box. This would indicate that the proposals are, in any case, unnecessary. However, by ignoring our existence and making no allowance for the very different character of our aircraft, I do not believe their proposals can do other than severely restrict our flying.

 

15) In 5.4.3 they state that, despite their “proactive negotiations”, they don’t know the details of DSGC operations, and yet they have somehow created a “Glider Box” to permit these unknown operations to continue!

 

In summary, I believe this proposal is ill-conceived. The airport has, obviously,not adequately consulted other local aviators, and many of us have been totally ignored. Details and conclusions seem to be sketchy or inaccurate (one area in CTA-4 is shown as starting at 300feet) and I wonder whether it is more of an ATControllers wish-list than a serious document.

 

If this selfishly ill-conceived plan is implemented the changes will severely limit our ability to aerotow hang gliders from Smeatharpe Airfield. Our main reasons for flying at Smeatharpe will be undermined, endangering the future of our operation. Free flight operations from all sites in the area will be severely limited for no good purpose.

 

If they really want to avoid impacting our operation, the airspace lower limit should be no lower than 5,000' QNH. In thermic conditions we need to be able to climb as high as possible over Upottery, and through the gap between the Dunkeswell and Exeter ATZs to cross N of Exeter.

 

Confining all GA traffic in the area to a limit of 3000 QNH (actually around 2000’ AGL) will actually increase the risk of incidents. Although I have no doubt it will make life easier for the Air Traffic Controllers at Exeter, for the Free Flight fraternity, this plan would be a disaster."

Ian Anslow
Ian Anslow's picture
Air Space

My reply is not a long as Simons but I hope it helps.

Cheers

Ian

 

 

To Whom it may concern,

 

I am a Paraglider pilot with a local Paragliding Club who have several flying sites (hills) which will be severely affected by the new Airspace proposal as well as several cross country routes.

I would like to voice my concern that our club has not been consulted with regards to the new airspace proposal. Our governing body The British Hang gliding and Paragliding Association (BHPA) has repeatedly tried to voice it’s concern at how negatively this affects us.

 

I am fully aware that the need for more control is evident however shutting down such a large area of airspace to all other aviation without any negotiation is not the answer.

 

I am hoping that we can at least voice our concerns and come to some agreement with regards to opening up blocks of airspace so we can still enjoy our aviation.

 

Regards

Ian Anslow

Simon Murphy
Simon Murphy's picture
Please respond!

It is very easy to post a response.  Apparently Exeter are saying there have been very few negative responses, so they need to be shaken out of their position of confidence.  There isn't necessarily any need to go into detail, just say what you think of the idea of our thermal flying being drastically curtailed.  A short and not-very-sweet comment may be more effective than my diatribe.

Just send your email to:  acpconsultation@exeter-airport.co.uk 

John Wreford
John Wreford's picture
Air space

Simon, I have sent this, John W.

Dear Sir/Madam,

I am a member of the Devon & Somerset Condors Hang-gliding and Paragliding club.

We fly along many coastal sites which will be severely impacted by the Airspace proposals.

I request that appropriate consultation is made with this club and others like it.

Regards, John Wreford (Treasurer)

Russell Andrews
Russell Andrews's picture
Me too

and I sent this;

Dear Sir Or Ms
It appears that very little consideration has been taken of the requirements of paragliders and hang gliders. 
 
As a paraglider pilot, a member of Devon & Somerset Condors Hang-gliding and Paragliding club and the South Devon Hang Gliding and Paragliding club, I would like to see more consultation, and more consideration and respect for, our activities.
 
There may well be scope for negotiation and agreement rather than a Sky-Grab which is how the proposals currently appear.
 
I look forward to a positive outcome for free-flyers, and for Exeter Airport and its employees.
 
Yours
Russell Andrews
(address etc)
Michael Rigby
Exeter Airport Airspace Proposal

Sent this this afternoon:-

Friday 9th June

Dear Sirs,

Having read the Exeter Airport Airspace Change Proposal document, you say that the consultation period closes on Thursday 9th June. The 9th of June is a Friday.

With regard to the proposals, I fail to see why a 20% increase in aircraft movements at Exeter Airport justifies increasing the airspace by the amount requested. As far as I can see, the proposal makes no mention of the current number of aircraft movements at Exeter. Nor does it state the current operating times allowed. Are these to remain the same? If they are to increase, why have you not stated numbers? It is hard to make a subjective assessment of the proposal without this information. Any discussion must contain hard numbers and not just woolly (imagined?) percentages.

Furthermore, can you tell us what consultations have been made with homeowners, together with those members of the farming community within the operating area with regard to increased noise pollution? Again it would be hard for these people to judge the effect on their environments without stating existing and proposed numbers of aircraft movements. Certainly no one from your organisation has canvassed my opinion on such matters of increased pollution.

I would suggest you revisit your proposal and furnish it with understandable, cogent data.

Yours Faithfully,

Michael Rigby

Budleigh Salterton.

 

Simon Vacher
My response in an annotated PDF

Here was my response, with a detailed annotated PDF document showing exactly how the proposed airspace would affect us - https://www.dropbox.com/s/6zsq7lrtjmp0c9s/Exeter_Airspace_grab.pdf?dl=0

Viv Fouracre
Viv Fouracre's picture
Exeter Airspace proposal

Below is the BHPA response, emailed to me yesterday by Tom Hardie, BHPA officer responsible for airspace issues. 

Date: Fri, 09 Jun 2017 23:57:00 +0100

Subject: RESPONSE TO EXETER ACP CONSULTATION

Dear Sirs,

 

1.     This email is the British Hang Gliding and Paragliding Association’s (BHPA) response to the Exeter Class D airspace proposal.

2.     THE BHPA
The BHPA represents some 7,000 pilots who fly hang gliders and paragliders, and their powered variants.  We represent over 90% of active UK participants.  For information about the Association and its members’ activities please visit www.bhpa.co.uk.

3.     THE BHPA’S POSITION ON THE CONSULTATION
The BHPA welcomes the opportunity to respond to the consultation however it has found itself prevented from reaching a reasoned and complete response due to a lack of pertinent information, including information directly requested from Exeter but never delivered.  This is more than a little disappointing as we are prepared not to object to an airspace change where it is justified.  In this case we are forced to object to the proposals as we can but find the need for the Class D airspace at best unproven.  We believe that had all the requested data been provided we would be objecting to the Class D proposals due to insufficient justification.

4.     FORMAL COMPLAINTS TO THE CAA
We have found the running of the consultation process so far to have been fundamentally flawed to the extent that we have taken the unprecedented step of submitting four formal complaints to the CAA.:
4.1.   An issue with a misleading initial consultation document was upheld, and a revised consultation document was issued
4.2.   The reissued consultation document was also misleading, the CAA have stated that they will consider this when/if Exeter submit their proposal to the CAA
4.3.   The lack of informal consultation with any hang gliding or paragliding group prior to the issuing of the formal consultation document, the CAA have acknowledged receipt and will no doubt consider it when/if Exeter submit their proposal to the CAA
4.4.   The lack of requested pertinent information, the CAA have acknowledged receipt and will no doubt consider it when/if Exeter submit their proposal to the CAA

5.     LACK OF INFORMAL CONSULTATION
Prior to a formal consultation CAP725 calls for informal consultations with stakeholders, both local and the relevant national bodies.  We could find no evidence of any contact with either local groups or the BHPA and so asked Exeter what contacts they had made.  They admitted that they hadn’t made any.

6.     MATURITY OF THE FORMAL PROPOSALS
CAP725 calls for the informal consultation so that formally consulted proposals can reflect the needs of all stakeholders.  This failure to follow CAP725 is highlighted in the agreed notes of the meeting between Exeter and the BGA where Exeter calls their formally consulted proposals a “starter for ten”.  Such an immature proposal is what should be the subject of the informal consultation.  We therefore again find that Exeter have failed to follow CAP725.

7.     LACK OF REQUESTED INFORMATION
We have made a number of data requests, some of which have been satisfied promptly and efficiently.  However some requests remain unanswered.
7.1.   In the consultation document there is reference to an analysis of some GA traffic.  We have requested the base data so that we can examine the conclusions reached in the consultation document.  Despite repeated requests all we have been given is Exeter’s analysis of an unseen set of data.  If Exeter’s analysis is sustainable then why have we not been provided with the base data?
7.2.   On the 11Apr2017 Exeter told us, “I believe controlled airspace should not be seen as a barrier to free flight.”
In order that we can assess the veracity of this belief we have repeatedly asked for details on how this might work but have so far received nothing.
7.3.   So that we can consider and address Exeter’s position we have repeatedly asked what issues any hang gliders or paragliders have created for Exeter.  The answers have been less than transparent but we believe we have received an acknowledgement that there have been no documented issues known to have been with any hang glider or paraglider

8.     MISSED OPPORTUNITY FOR SIMPLE ENVIRONMENT BENEFITS
It is acknowledged by the Department for Transport, the CAA, and virtually all Air Navigation Service Providers (ANSPs) that there is a need to reduce environment impacts when the opportunity occurs.  Almost inevitably steepening approaches and departures is good for the environment and fellow airspace users.  Exeter’s instrument procedures could be easily improved to everyone’s benefit yet Exeter has apparently opted to continue with its outmoded existing ones.  With a little effort they could be even larger benefits.

9.     MEETINGS WITH LOCAL OPERATORS
In April, after the issuing of the Formal Consultation document Exeter offered to meet with local BHPA groups but failed to provide any response as to what benefit it was expected to gain from discussions so late in the process that would not be satisfied by responding to the Formal Consultation.  Therefore no meetings took place.

10.  IMPACT UPON BHPA MEMBERS
As acknowledged by Exeter there is no know incident where a paraglider or hang glider has caused an issue.  Therefore to have an airspace proposal that effectively excludes hang gliders and paragliders from large volumes of airspace can hardly be described as an evidence and risk based proposal.
 

 

Viv Fouracre
Viv Fouracre's picture
Exeter airspace decision

Good news, the application by Exeter was refused. Link to CAA is here - https://www.caa.co.uk/Commercial-industry/Airspace/Airspace-change/Decis... - but I have attached the decision doc.