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Civil Aviation Authority submission of 11 February 2022

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

Thank you for your letter of 7 February 2022 to Richard Moriarty where you sought, on behalf of the Citizen Participation and Public Petitions Committee, the CAA’s views in relation to statements made in the petition calling on the “Scottish Parliament to urge the Scottish Government to halt Highlands and Islands Airports Ltd’s Air Traffic Management Strategy Project to conduct an independent assessment of the decisions and decision-making process of the ATMS project.”

Some elements within the text of the petition are beyond the remit of the CAA, so our view will be limited to those aspects that fall within our horizon. Namely:

1. The provision of surveillance capability to support the Air Traffic Management Strategy (ATMS),
2. The provision of services at multiple airports from one controlling position.

Aspects of the petition related to airspace change fall within the scope of the CAP1616 process and progress for individual applications is made publicly available through the CAA’s airspace portal.

Currently, surveillance throughout the UK is based on a set of layered surveillance capabilities made up of both cooperative (requiring both ground and airborne equipment such as secondary surveillance radar (SSR)) and non-cooperative (requiring only ground-based systems such as primary surveillance radar (PSR)). Although there are occasions when cooperative surveillance is the sole radar source used in the provision of an ATC service, these occasions are limited to those times when the primary (non-cooperative) radar has become temporarily unavailable. Currently CAP670 - Air Traffic Services Safety Requirements states that, below FL100 “All Terminal Control Areas shall have at least a single layer of coverage by a suitable non-co-operative surveillance technique”. It further states: “non-co-operative surveillance is required wherever an ATSU providing surveillance-based air traffic services identifies that it is probable for non-transponder equipped aircraft, whether identified or not, to present a hazard to operations due to the uncertainty of their positions”

Although, the text currently within CAP670 inhibits the provision of an ATC service based solely on non-cooperative surveillance, under the Civil Aviation Authority (Air Navigation Directions) 2017, as amended (the Air Navigation Directions), the Secretary of State has given the CAA the function to prepare and maintain a co-ordinated strategy and plan for the use of all UK airspace for air navigation up to 2040, including for the modernisation of the use of such airspace. The Airspace Modernisation Strategy (AMS) – CAP1711 states that “there are opportunities that allow for the phased modernisation of the UK’s surveillance capability”. Further developments to the Airspace Modernisation Strategy are currently under consultation.

While cooperative surveillance, as a standalone solution in the provision of air traffic services, is not something the CAA would consider in this case in the near term, the Airspace Modernisation Strategy strives to enable its wider use in the medium to long term and HIAL have been advised to scope trials or studies to assist in realising its benefits and bringing the Airspace Modernisation Strategy to life. The issues highlighted during the 12 January meeting relate to the timing of the implementation rather than overall possibility.

With regards to plans for a single controller to offer services at multiple airports simultaneously, the CAA considers the proposal to be feasible, but not without some limitations. HIAL are aware that there may be conditions or limitations placed on the ATC services offered by the proposal. HIAL have a mature and established safety management system (SMS) and have experience in implementing changes of this nature. Specific details of the change are not expected to be submitted to the CAA for some time, but the CAA will review the safety arguments related to the proposal when they are submitted. Any proposed change will be subject to approval from the CAA.

I hope the text above assists the Citizen Participation and Public Petitions Committee in their deliberations, at least in those aspects related to CAA activities.