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Petitioner submission of 9 June 2021

PE1804/MM - Halt Highlands & Islands Airports Ltd's Air Traffic Management Strategy

HIAL has stated that providing an Aerodrome Flight Information Service, (AFIS) rather than Air Traffic Control (ATC) at Benbecula and Wick is an extension to what happens at present. We believe that this statement is inaccurate and mis-leading.

Presently, at HIAL ATC airports, except Inverness, Scottish Air Ambulance and flights conducting search and rescue operations have a UK Air Navigation Order (ANO) exemption to enable their pilots to fly the Instrument Approach Procedures, (IAPs) that is bad weather approaches, without the provision of ATC during periods when the airports are officially closed. Aerodrome Flight Information Service (AFIS) is routinely substituted in lieu of ATC during these times. During these ‘special openings’ no other conflicting instrument flights (IFR) will routinely be operating. Deconfliction of the IFR Air ambulance flight with any other IFR traffic at the airport is therefore not an issue.

HIAL continue to compare Benbecula and Wick operations with those at Islay. This is not the case in terms of IFR traffic numbers and mix.

The CAA has recently approved a change at HIALs AFIS aerodromes at Barra, Campbeltown, Islay & Tiree. The revision is a system involving booked airport slot times and prior permission required (PPR). HIAL has provided the CAA with a ‘Statement of Need’.

This is summarised as:-

• HIAL operates 4 aerodromes where the provision of Air Traffic Services is provided under the auspices of AFIS.

• The aerodromes have discreet (not published) terrestrial based IAPs and published RNAV ("Random" Area Navigation)/ GNSS (Global Navigation Satellite System) procedures.

• These 4 aerodromes operate under a UK Air Navigation Order (ANO) Article 172 exemption. (Note: This should state Article 183. We understand that this HIAL error has now been corrected by them.)

• HIAL operational experience and evidence to date has highlighted significant use of the published RNAV/GNSS approaches without HIAL approval.

• The present ‘approved operator only’ is either misunderstood, not noticed, or ignored. This results in pilots utilising the RNAV/GNSS procedures without contacting AFIS (by radio) or HIAL approval, often resulting in instances of airborne conflict with IFR scheduled traffic and at significant risk to either party.

• Part of the safety justification behind the ANO exemption, was for IFR traffic to be subject to slot times to avoid airborne conflict. (IAPs are normally only permissible at aerodromes where ATC is provided)

• The application of a ‘strictly PPR’ note to the approach plates is clear and unambiguous and should present the AFIS Units with the opportunity to enhance traffic management and allocate slot times in order to deconflict IFR traffic.’

We believe that in this statement HIAL effectively admit that the provision of ATC is the norm at airports where IAPs are published.

ATC provides a flexible system using various techniques to deconflict and expedite IFR traffic. AFIS cannot use these techniques.

Where there are often concurrent IFR flights operating in bad weather, such as at Benbecula or Wick, a system where AFIS is expected to rigidly enforce slot times, will inevitably cause excessive delays. These will occur particularly on the ground to avoid airborne conflicts. The knock-on effect will be a lack of public confidence in using the airport or the carrier, as travellers will wonder where the ‘’problem’’ lies.