Seòmar agus comataidhean

Petitioner submission of 31 January 2022

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

One of the original aims of this Petition was to ask the Scottish Government to conduct an independent assessment of the ATMS project. This is more urgent than ever given the recent announcements made by HIAL and the Prospect Union in the last few days. My reasons for saying this are as follows;

HIAL have said that they are now working on alternative delivery options for ATMS, with radar surveillance for ATC centralised in Inverness. Tower Controllers will remain at the Airports. A working group will discuss options for Benbecula and Wick.

Details will be worked out, a new Business Case will go to Transport Scotland, a new Island Impact assessment will be done. HIAL are happy, the Prospect Union are happy.

I am not. Neither should anyone else be. So far £9 million pounds has been spent with little achieved.

In submission PE1804/RR I raised a number of concerns. Below are more.

Central to HIAL's plans to modernise ATC is the implementation of surveillance radar.

The Committee asked HIAL about Primary Radar costs. HIAL replied in evidence PE1804/TT saying that Primary radar is not required as HIAL will use cooperative surveillance only. HIAL state the CAA can see no obvious impediment to this type of surveillance being used in the future.

Minutes from the CAA/HIAL meeting on 12th Jan 2022 regarding the Wick airspace change proposal suggest that the evidence HIAL submitted is misleading.

The CAA state at the meeting that many documented conversations have taken place with HIAL regarding cooperative only surveillance. The regulatory environment for providing ATC using cooperative radar only doesn't exist and using it was not viable as far as the CAA were concerned. The CAA would write to HIAL with confirmation that the current regulations do not permit HIAL’s preferred solution.

I suggest the Committee ask the CAA to provide them with copies of any correspondence between HIAL and the CAA regarding cooperative radar.

Without radar surveillance HIAL will be unable to modernise the way ATC is currently being provided.

Controlled Airspace at ATC airports is another of the aims of ATMS.

Inverness started its Airspace Change process in April 2013. On 13th October 2021 HIAL met the CAA to discuss various items including the implementation date. The CAA requested a number of items be addressed before a decision could be made.

In January 2022 HIAL sent a letter to the CAA saying that Inverness felt it was appropriate to propose a delayed implementation if the Airspace Change was approved.

It is unclear to me when the CAA will reach a decision on whether or not Inverness will be granted Controlled Airspace. It is also unclear to me that if it is granted, when will HIAL implement it.

Does HIAL still intend to introduce Controlled Airspace at Dundee, Stornoway, Kirkwall and Wick?

If so, could it take 9 years to reach a conclusion, which is the time taken so far for Inverness.

Benbecula and Wick downgrade from ATC to AFIS.

HIAL have informed the CAA that downgrading Wick from ATC to AFIS is likely to increase the potential risk of airborne conflicts. To mitigate the risk HIAL intend to have one Radar Controller providing an approach service to both Kirkwall and Wick at the same time. The CAA have commented to HIAL that using one controller for 2 airports simultaneously is not currently in place in the UK so would need to looked at. As mentioned above, HIAL have also to decide how to meet CAA radar surveillance requirements. Until such time as these issues are resolved Wick cannot be safely downgraded to AFIS.

Benbecula ATS staff are still refusing to cooperate with HIAL management. The proposed downgrade is subject to separate Union negotiation and working groups are to be appointed. Previously submitted evidence regarding the downgrade at Benbecula still applies.

HIAL will now locate the Combined Radar Surveillance service to Inverness Airport.

The building HIAL intend to use is a 60+ year old concrete shed currently being used as a store by the airport electricians. HIAL bought and renovated New Century House in Inverness city at a cost of £3.6 million so it could house the Combined Surveillance Centre and Remote Tower Centre. Why has using it been abandoned in favour of a semi derelict concrete shed? What do HIAL intend to do with New Century House?

Why centralise Radar Surveillance to Inverness anyway? Despite what HIAL say, it is perfectly possible to have the radar controllers at each airport with only a few extra Controllers. Is there any credible evidence that Inverness is the best place to centralise radar controllers?

ATMS centralisation was meant to solve HIAL's perceived recruitment and retention problems. Now that Tower Controllers and assistants will be remaining at the airports, will HIAL commit to recruiting and training new staff from the communities local to the airports?

Digital Audit Scotland have submitted a second report to HIAL and the Board have been informed that ATMS remains a Red/Amber risk. Seven actions have to be taken by HIAL. When will this report be published to the HIAL website?

I would welcome the opportunity to discuss my concerns with the Committee in person.