Episode 2

Published on:

14th Jul 2022

Our review of airspace in the Cotswold region

We have now published our final report on our review of airspace in the Cotswold region. Join Nikki Deeley and Emma Simpson from the Airspace Classification team to learn more about which volumes of airspace the process will seek to amend, as well what other activities can be used to improve UK airspace.

For more information see

Cotswold region final findings report 2022

The airspace classification information on the CAA website


Alex Coleman 0:11

Hello, welcome to the CAA's GA podcast. My name is Alex Coleman, and I am the Airspace Stakeholder Engagement Manager. Today we're joined by Nikki and Emma from our Airspace Classification team, and they're going to guide us through all of their work in the Cotswolds region. Hi, Nikki, hi Emma, perhaps you can begin by introducing yourselves for us.

Nikki Deeley 0:43

Hi there. I'm Nikki Deeley, I lead the Airspace Classification Review team.

Emma Simpson 0:47

And I'm Emma Simpson, I'm the Airspace Lead on that team.

Alex Coleman 0:51

Thank you very much. Okay, perhaps for those who haven't heard of you, or are new to this, you might be able to sort of tell us a little bit more about what the Airspace Classification team does.

Nikki Deeley 1:01

So we are a relatively new team in the CAA. We were brought in at the start of '21 to review the classification of airspace in the UK. And this is following directions from the Secretary of State where they wrote to the CAA and asked that the CAA should consider whether to review airspace classification and consult airspace uses as part of that review and then where we consider that an amendment needs to be made to the classification of airspace that we do so in accordance with a new procedure. And while our intention was to review the whole of the UK airspace, we took a decision quite early on, to focus our task on specific regions to give the airspace that greater scrutiny and to make it much more manageable for us and our stakeholders. And perhaps Emma would like to describe a bit more about how and why we took that decision.

Emma Simpson 1:47

Yes, sure. Hi. So like Nikki said, it was a pretty big ask in terms of reviewing the airspace across the entire FIR and there's a relatively small team and newly formed, we felt that it would be significantly more achievable to do this in a more focused way. So we took the recognized boundaries of the existing altimeter setting regions as a baseline, and then chose the Cotswolds as our starter, and tweaked the boundaries marginally to apply some logic to how the airspace is delineated. Then we conducted our own deep dive into who uses the airspace, why they use the airspace, how they use the airspace, any safety concerns and equitable access. And we were able to then focus and come up with our review,

Alex Coleman 2:35

What made you go for the Cotswolds in the first place?

Emma Simpson 2:37

The Cotswolds was of an interest to the Airprox Board. And we also inherited the legacy consultation. A lot of the comments in the legacy consultation had referenced airspace that sits within that Cotswold boundary. We also felt that the Cotswolds region would be manageable in terms of complexity, usage, and looked at the stakeholders involved. And, as mentioned, it had some safety areas of interest. So we thought that was a good place to start

Alex Coleman 3:08

For the legacy consultation, because I'm old enough to remember when that went out, and that covered the whole of the UK, that was still helpful?

Emma Simpson 3:15

Absolutely, we received over eleven hundred comments relating to volumes of airspace within that consultation, every single one of those has been reviewed, analyzed. And what's really key from that particular survey is that we've had some brilliant steers as to where we should focus and why. At the time, we didn't have our analyzer tool up and running. And so therefore a lot of the responses, we were not able to back up with evidence. But as we move around regions we have and we will continue to pull those responses. They're all already filed. So we've therefore divided them up stored them, according to region. There are some incredibly insightful and really useful comments within there, which have definitely helped to steer us and enable us to understand how our airspace is used. What's been brilliant is that we as an organization have learned about how better to shape consultations, which in turn helps to shape the increased quality of the responses. And as we've gone along the Cotswold investigation, certainly the surveys we've conducted specific to that region have been incredibly helpful and useful and pertinent and full of really good evidence and data. So that's been great.

Alex Coleman 4:38

Thanks, Nikki, anything to add on that one?

Nikki Deeley 4:41

We received a lot of comments that related to ongoing Airspace Change Proposal programs, so ACPs, and our process says that where there's an ongoing ACP in the early stages before that airspace design has been decided, that we can't make any changes in that area. So we took that insight for those ACPs, we packed them up per change sponsor, and we handed out information. So all the consultation comments we received, we provided that to the change sponsors. And that was given to them with the expectation that they should consider those responses as part of the ACP process. And we've got the Airspace Regulation team within the CAA who now look for that through one of their Gateways to ensure that that change sponsor has taken that insight into account.

Alex Coleman 5:28

Fantastic. Thank you. So the last we heard from you was early this year when you published your draft report into the Cotswold region, which had lots of helpful insights and you invited comment on that. I understand you're now publishing your final report, which is why we brought you on today. What's changed since you've published your draft report what's been going on since then?

Emma Simpson 5:47

So CAP twenty-three fifteen was, as you say, the report detailing our draft findings from our investigation and analysis of Airspace usage within the Cotswolds region. Within that document, we included our initial plan, which comprised of a list of volumes of airspace, where we felt that there was potential for that to be taken to the amend phase, since that has been published, that was published in January, and also accompanied by a survey where we were requesting feedback upon our draft findings. We analyzed the responses in the survey, we continued to engage with ACAs, we conducted further investigation of those volumes. And not to mention all of the meetings that we attend, whether it's the Infringement Coordination Group, local airspace infringement team work, engagement with UKAB, engagement with internal agencies within the CAA, and ultimately, that's allowed us to hone it down into the volumes where we are able to take, or the volume where we can take, into amend as well as detail in our final report, what's happened to the other volumes that were on the initial plan and are no longer going to go to amend.

Alex Coleman 7:04

So just to be clear, there's one volume being amended at the end of all this work. Is that right?

Emma Simpson 7:10

So there is one volume that's going to be taken through to the CAP nineteen ninety-one process. That's Daventry CTA six. And yes, I'm smiling, but you listeners won't be able to see that because that question was put to me in a slightly less blunt way when I attended the Gatwick LAIT fairly recently, and one of the attendees had said you knew we recognize there's been an awful lot of work, hard work, in depth analysis, but it seems like an awful lot of work to produce one volume to go into amend. And yeah, absolutely, I can see why that perception exists. Our final report explains in detail as to what's happened with the other volumes that are featured on the initial plan. I hope that listeners will take the time to read the whole report because it's taken a lot of work to put that together. But certainly the first section which explains what we have been doing in the last few months and our reasons behind not taking volumes forward. When we kicked off the focus in the of the airspace usage and the Cotswold, our focus clearly on safety and equitable access, that caused MOD to instigate their own defence airspace suitability review, and that's UK wide. And from that they revisited their own airspace volumes, and were able to justify or in some cases present us with some volumes elsewhere with the Cotswold region for change. But one particular one that featured in our initial plan was the Delta 147 Pontrillas danger area. Our initial analysis using our tool, taking into account legacy consultation responses, and other information sources demonstrated that it did not appear to be utilized in such a way that it would justify H 24 status and a level of surface to 10,000 feet.

Alex Coleman 8:57

Sorry, what's H24 status,

Emma Simpson 9:00

Apologies, that's activated 24 hours a day. So one thing about equitable access is is the airspace fit for purpose? Obviously, safety is paramount. But we have to assess whether the hours of operation and the dimensions of the volume are fit for the task and that other airspace users are not being adversely affected. So this Delta 147 was a real prime example of how we went to MOD with our findings. And MOD went to the danger area owner and asked for all the detail of what happens there and when it happens and what levels are required. And we were satisfied with what they came back with that that airspace is entirely fit for purpose, and therefore we move on. One of the more recent survey responses had expressed concern that we've and I quote, "clearly been stonewalled by MOD". I just really like to stress that that's not the case at all. They're working incredibly closely and well with us understand and spreading the word that equitable access wherever possible is the way that we have to go and if that means switching airspace on and off, or better publicizing the frequency to call to get the crossing clearance, then that's what we're going to do. So we're really are holding ACAs to account and we will be continuing to do so. And revisiting our recommendations in 12 months time to make sure that people are doing what they've said that they're going to do.

Alex Coleman:

You mentioned briefly there with the MOD in terms of not stonewalling. But how have you found working with stakeholders on this over the past year? Have they been open to the idea? Has it been difficult? Have you sort of built those relationships up?

Emma Simpson:

One thing I have been slightly taken aback at since I've taken on this role is how adversarial it can get in conversation between various stakeholders about airspace usage, and whether it's fit for purpose. I know that I'm trying very hard from the meetings that I attend, be it at the Regional Airspace User Working Groups, or the LAITs or whatever opportunity, we have to engage with all stakeholders, to encourage them to understand each other's wants and needs, and to just have grown up conversations, and to try and build trust, really, and also to make sure that any underrepresented stakeholders, that their voice and their wants and needs are also accommodated. It's quite hard to quantify and demonstrate the outcome of that work. But that's certainly a big part of what I've been doing over the last 12 months.

Nikki Deeley:

It's probably worth adding when we talk about having grown up conversations. And one thing that's really aided our ability to do this is our new Analyzer tool. And it is really adding credibility to the conversations we're having and demonstrate to them, you know, we're taking this seriously, we want to understand how the views that we're hearing are corroborated by the data that we're seeing and whether we can then take that information, that insight and challenge back to the airports that might say that they need this airspace or the military so that they're using this airspace, we can say, Well, look, we have this tool, what we're looking at shows that perhaps you don't need it, or you don't need it at those times. Let's have a conversation about that. So our tool is enabling those grown up conversations that Emma talked about.

Emma Simpson:

Yeah, absolutely. But we're also very aware of the limitations of the tool in that if any aircraft is not electronic conspicuity equipped, then we're not going to see them. But what that absolutely does, as Nikki said, was to allow us a really strong starter for 10 in any conversations, and we take it from there. And actually one thing I have encountered is that everybody's really willing to listen and work with us to make airspace fit for purpose, especially if the CAA are able to provide some of the resource to make that happen.

Alex Coleman:

How about internally, for the, more or less, the first sort of time the CAA is going to be put in position where they'll have to be marking their own homework, as some people refer to as you're gonna have to make some decisions about those amends, so you're gonna propose it and approve it, hopefully, surely, that must have been quite a difficult line to tread.

Nikki Deeley:

Absolutely. And it's a line we want to make sure we tread carefully. So we the Airspace Classification team are a sponsor of any changes to airspace classification. So when we've identified a volume of airspace that we believe needs to be amended, we need to go through a set process set out in CAP1991, where we examine the options for change, we examine the impacts, pros and cons of those options. We look at the environmental assessment, safety assessment, operational impact assessment, we gather all of this data together, we then have to consult on that information. And our preferred proposal. Insight from that consultation then forms our final submission, we then submit that to our Airspace Regulation team. Yes, they are a team within the CAA. But we're working very carefully, and we set up our own memorandum of understanding with them, to ensure that that relationship with them, when they come to review our submission, it comes in the appropriate manner, but we're keeping that relationship appropriate and transparent. So any formal conversations that we have with them, we'll make sure we keep a record of those. But it has taken time. First, because the Airspace Regulation team are used to working with CAP 1616, that is their life, they've now got a new process, which they need to make a decision on. And they've needed to learn that process and understand how our process differs from the one that they're used to. So there's been some time taken to kind of bring them on that journey, probably a long winded way of saying that we've worked hard to ensure that we have an appropriate relationship with our regulator and bring them on that journey. And it has taken time. But we think we're in a better place for it.

Emma Simpson:

For me, it's just been really clear that anybody involved internally is just so keen to do the right thing, and for it to be documented. But meanwhile, we're conducting the review. And we're pushing on with the process. So lots of work going on in the background. But again, it's all from a very good place of making sure that we tread the line in an appropriate way.

Alex Coleman:

Thank you. I just one more question from before we move on to your plans for the future and where you're going to begin looking next. It seems to me that the process has evolved changed a bit over the past year, and you've gone above and beyond just identifying things that you can amend through the amend process. Just wondering if you can give a little bit more detail as to what other things you've done and how the process has changed throughout the year.

Emma Simpson:

So I guess what you're alluding to is something that I've tried to document in the front of the final report, which is the impact of our work and how it stretches beyond changes to the classification and a huge part of this has been laying the foundations and building trust and credibility, making sure that we as a team know where we sit within our own organization. But then it's also engaging in a really positive and constructive way with all stakeholders, which ultimately will foster a better sharing of airpace. And that's really apparent from when I am speaking to, you know, there's often a queue of people wait to speak to me in the margins of meetings. And it's really, really positive. I take loads back and lots of actions. And you know, we don't know what we don't know. So if people tell us make us aware, we can go and do something with it. And it's just really trying to encourage that flow of communication and building strong relationships with again, all stakeholders, particularly ACAs, and letting them know that we're not here to wield an axe through huge swathes of airspace, and start generating a massive resource load for them. That's not what it's about, it's where can we help? Is the airspace fit for purpose?

Our findings have demonstrated education is required, everybody involved in airspace has a responsibility to fulfill their own obligations. And whether that's appropriate and thorough flight planning, making sure that the documents that anybody is utilizing are up to date, along with our investigations, it's been brought to our attention, or we've discovered for ourselves that some of the information, the aeronautical data in the AIP, is perhaps ambiguous, or in some occasions inaccurate. Within the CAA, an AIP working group has been established, we're feeding in our findings for that. So that's going to filter through the system and make improvements there. And we work closely with the infringement team and UKAB. Again, we're supporting and reinforcing their education work with the ultimate aim to promote safety and encourage good airmanship. So overall with our Analyzer tool, with the attendance at the meetings with the opportunity to get out and you know, engage at grassroots level whilst also engaging at the top levels of all of these organizations were hopefully helping to bring about positive change. And with that, as we continue to review airspace, we will be able to make some classification changes as well.

Alex Coleman:

Thank you. So Okay, moving on, what next? Where next? What's the plan?

Nikki Deeley:

So as Emma mentioned, we'll be taking Daventry CTA 6 through the amend phase of our process, as well as progressing the other changes that we've already mentioned. And while that amend work is ongoing, we will start to look to our next region of focus. And we're planning on moving to the north of England, and will shortly be asking for insight on that to help inform our work. At the outset, we intend to ask for information and further evidence on what's going on in the Manchester Lower Level Route. This has been highlighted as a particular area of interest to the CAA. And also where we're not directly involved in some of the changes that we've proposed in our report, we will be ensuring that we get back on how that work is progressing. So Emma mentioned changes to the AIP, and the military's danger area review, we will be checking to see where that work has got to. We've also made recommendations for changes that will go through different processes, through the CAP1616 process, and we will check in and determine where that work has got to.

Emma Simpson:

And finally, we've as a team taken ownership and revamped the process for the Refusal of Service form the FCS1522. And we're getting great feedback on that. But again, I just really can't request strongly enough that pilots file them with us and let us know what's going on. Because we will get back to you. We will report back having conducted the investigation internally and then with the airport or the ANSP in question. Because then we build up a database. And so it's all really good stuff that allows us to build a credible picture.

Alex Coleman:

And you can find that form on our website. Can you? Yes, absolutely.

Emma Simpson:

Search for FCS1522. And one thing, although I'm advised not to read any of the forums, sometimes I can't help myself. And there was one thread I noticed recently with discussion between aviators as to whether there's any value in filling out this form, there was a lot of negativity about what happens when they perhaps press send, and what happens within the CAA. And the the individual did file the form. And our safety lead on the team dealt with it. And they individual who'd filed it did go back to that forum and expressed surprise that he not only received a response, but it was prompt and it was detailed. I just need people to speak to us. Tell us what you know, so that we, where can our attention and focus go? And at the very least if you've have experienced a refusal of service, pop it into the form and we can look into it and we can build an evidence case. It goes to the ATS inspectors, we will take action, but we can't take action if we don't know about it.

Alex Coleman:

Well, thank you both very, very much for your time, I'm sure our listeners will have found out very interesting and helpful. Obviously, if people do have any questions about airspace classification and the work we're doing, our best to contact airspace.classification@caa.co.uk. And also, if you have any more general questions about our work at the CAA or any suggestions for what you'd like to hear about in future episodes of the GA podcast, please email us at GApodcast@caa.co.uk. Thank you and goodbye

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CAA on General Aviation
The General Aviation podcast brings you the latest guidance from the UK Civil Aviation Authority with information for all types of General Aviation (GA) operating in the UK. Including updates and discussions on our current projects and areas of work.

You’ll hear interviews with representatives from our GA teams, experts on their particular fields, sharing details of their work and regulatory updates as well as highlighting opportunities for members of the UK GA community to get involved.

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