Walney Offshore Airspace Change Framework Briefing

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1 Walney Offshore Airspace Change Framework Briefing Date: 21 May 2014 Author: Revision: Issue 1 Osprey Ref: This document is of UK origin and has been prepared by Osprey Consulting Services Limited (Osprey) and, subject to any existing rights of third parties, Osprey is the owner of the copyright therein. The document is furnished in confidence under existing laws, regulations and agreements covering the release of data. This document contains proprietary information of Osprey and the contents or any part thereof shall not be copied or disclosed to any third party without Osprey s prior written consent. Osprey Consulting Services Limited 2014 The Forge, London Road, Bentley, Hampshire. GU10 5HY / enquiries@ospreycsl.co.uk Registered in England and Wales under No:

2 Document Details Reference Document Title Description Walney Offshore Airspace Change Framework Briefing Document Ref Issue Issue 1 Date 21 May 2014 Client Name Classification DONG Energy Restricted Issue Amendment Date Issue 1 (Redacted) 9 Jan May 2014 Approval Level Authority Name Author Internal Approval Client 1 Approval Client 2 Approval Osprey CSL Osprey CSL DONG Energy BAE Systems Document Details 2

3 Executive Summary DONG Energy (DONG) wish to develop an extension to the existing Walney Wind Farm, referred to as the Walney Offshore Extension Wind Farm (WOW03). The project development site will be located in the East Irish Sea, in close proximity to the Walney Wind Farms (Walney 1 and Walney 2) the operational offshore wind farms which are north of Morecambe Bay, approximately 35 kilometres (km) (18.9 Nautical Miles (NM)) northwest of Fleetwood and Blackpool, and 31 km (16.7 NM) east of the Isle of Man. DONG is the sponsor for the proposed airspace change herein detailed. The presence of the WOW03 Wind Farm would affect BAE Systems (BAES) Warton Aerodrome (Warton) flying and Air Traffic Service (ATS) operations, and potentially those of BAES at Barrow/Walney Island Aerodrome, thereby requiring a change to the arrangements and procedures in the immediate airspace surrounding the Wind Farms. DONG has engaged Osprey Consulting Services Ltd (Osprey) to project manage the Airspace Change Process on their behalf. Impact The most significant impact on the Warton Primary Surveillance Radar (PSR) and its operational environment from Wind Turbine Generators (WTGs) is the risk of wind turbine generated radar returns causing false target generation and track seduction. False or seduced tracks (which in many cases are indiscernible from real tracks) may cause disruption by forcing Air Traffic Controllers to take action in order to maintain radar separation in accordance with standards mandated by the CAA when providing an Air Traffic Service Outside Controlled Airspace (ATSOCAS). Any loss of radar performance in this area along with any misleading or unnecessarily distracting displayed radar information have the potential to erode levels of safety. Options In developing the plans to resolve the issues detailed in Section 2, DONG has considered a variety of options to determine how best to meet the needs of BAES Warton as well as other aviation and non-aviation stakeholders. In the event that no mitigating actions are taken for the WOW03 development, it is likely that this would influence the PSR service at Warton in the ways described below. WTGs located within PSR coverage can reduce the ability of the radar to detect aircraft. The WTGs present themselves as a large number of reflecting moving targets to the radar, which look very similar to aircraft radar returns. Each of these effects reduces the effectiveness of radar in detecting targets, which can result in misidentification of aircraft, loss of track position, loss of track identity and false plots. These in turn can potentially cause serious safety and operational issues. Warton s preferred solution is to establish a Transponder Mandatory Zone (TMZ) with associated PSR suppression of the WTG reflected echoes of WOW03 and a 2 NM buffer zone around the operational Walney and its proposed extension, Ormonde, Barrow and the under construction West of Duddon Sands Wind Farms. This would avoid issues with visual confusion Executive Summary 3

4 from the air, difficulty in navigation chart interpretation and visual depiction on ATC video display screens. The north-eastern boundary can be adjusted to obviate issues associated with the Barrow/Walney Aerodrome Traffic Zone (ATZ). The ceiling of the proposed TMZ would be Flight Level (FL)100 and active within the Warton Lower Airspace Radar Service (LARS) provision times. However, the active times of the proposed TMZ can be adjusted to suit the opening times of other Airports surrounding the Morecambe Bay littoral area. Executive Summary 4

5 Table of Contents 1 Glossary Introduction General Purpose and Scope Document Structure Background and Justification Overview Background Aims Justification Options Considered Overview Option 0 Do Nothing Option 1 A PSR Solution Option 2 Radio Mandatory Zone (RMZ) Option 3 Secondary Surveillance Radar-Only Option 4 Primary Surveillance Radar Blanking or NAIZ Only Option 5 A TMZ with associated PSR Suppression Techniques Conclusion Development of the Proposed TMZ Overview Aim TMZ Boundary Requirements and Operation Vertical Extent of the TMZ Hours of Operation of the TMZ Implementation Work to Date Potential Impact on Airspace Use Overview Impact on Military Operations Impact on Civilian Aerodromes Impact on Light GA operations Impact on Offshore Helicopter Operations Environmental Assumptions and Economic Implication Table of Contents 5

6 7.1 Overview Economic Benefit Consultation Plan Overview Consultation Methods Consultation Programme References A1 Aircraft Operated from Warton A1.1 Typhoon A1.2 Tornado A1.3 Hawk A1.4 Jetstream A1.5 Unmanned Air Systems A1.6 Commercial Passenger Operations A2 Morecombe Bay Airspace Diagram A2.1 Morecombe Bay Offshore Area A3 Proposed TMZ Co-ordinates A3.1 Proposed TMZ Co-ordinates A4 Walney Offshore Airspace Change Project Plan A5 Stakeholder / Consultee List A5.1 Aviation Consultees A5.2 Aerodromes / Local Aviation Consultees A5.3 Non-Aviation Consultees: National Bodies A5.4 Non-Aviation Consultees: Regional Council Authorities A5.5 Non-Aviation Consultees: Council Wards / Local Authorities A5.6 Information Organisations: Members of Parliament A5.7 Information Organisations: Civil Aviation Authority Table of Figures Figure 1 Walney Proposed TMZ including 2 NM Buffer Zone Figure 2 Morecambe Bay Airspace and TMZ Figure 3 Morecambe Bay Airspace and TMZ Option Table of Contents 6

7 Table of Tables Table 1 Glossary of Terms Table 2 Table of References Table 3 Walney TMZ Co-ordinates Table 4 TMZ Proximity to Military and Civilian Aerodromes Table of Contents 7

8 1 Glossary Acronym AARA ACAS ACP ADR AEF agl AIP AOA AOPA ARA ATC ATM ATSOCAS ATS ATSU ATZ BA BAA BABO BAES BALPA BATA Meaning Air-to-Air Refuelling Area Airborne Collision Avoidance System Airspace Change Process Advisory Route Air Experience Flight Above ground level Aeronautical Information Publication Airport Operators Association Aircraft Owners and Pilots Association Advisory Radio Area Air Traffic Control Air Traffic Management Air Traffic Service Outside Controlled Airspace Air Traffic Service Air Traffic Service Unit Aerodrome Traffic Zone Blackpool International Airport British Airports Association British Association of Balloon Operators British Aerospace Systems British Airline Pilots Association British Air Transport Association Glossary 8

9 BBAC BBGA BGA BHA BHPA BMAA BMFA BPA CAA CAP CAS CAT CO 2 CTA CTR DAATM DAP DCA DONG DfT DIO ELFAA FJ FL FUA GA British Balloon and Airship Club British Business and General Aviation Association British Gliding Association British Helicopter Association British Hand Gliding and Paragliding Association British Microlight Aircraft Association British Model Flying Association British Parachute Association Civil Aviation Authority Civil Aviation Authority Aeronautical Publication Controlled Airspace Commercial Air Transport Carbon Dioxide Control Area (Class D UK Airspace) Control Zone (Class D UK Airspace) Defence Airspace and Air Traffic Management Directorate of Airspace Policy (part of the CAA) Directorate for Civil Aviation DONG Energy Department for Transport Defence Infrastructure Organisation European Low Fares Airline Association Fast Jet Flight Level Flexible Use of Airspace General Aviation Glossary 9

10 GASCo GAT GAPAN GATCO HCGB HQ DAAvn ICAO IFP IoMA IoMG LAA LARS LJLA LoA MAA MoD MTWA NAIZ NATMAC NATS NERL NCHQ NM NO 2 NOTAM OAT General Aviation Safety Council General Air Traffic Guild of Air Pilots and Air Navigators Guild of Air Traffic Control Officers Helicopter Club of Great Britain Headquarters Director Army Aviation International Civil Aviation Organisation Instrument Flight Procedure Isle of Man Airport Isle of Man Government Light Aircraft Association Lower Airspace Radar Service Liverpool John Lennon Airport Letter of Agreement Military Aviation Authority Ministry of Defence Maximum Total Weight Authorised Non-Automatic Initiation Zone National Air Traffic Management Advisory Committee The National Air Traffic Service Provider NATS En-Route Ltd Navy Command Head Quarters Nautical Miles Nitric Dioxide Notice to Airmen Operational (Military) Air Traffic Glossary 10

11 PANS PIR PPR PSR RAF RMZ SARG SRG SSR TMZ UAS UAV UKAB UKFSC WOW WTG VGS Procedures for Air Navigation Services Post Implementation Review Prior Permission Required Primary Surveillance Radar Royal Air Force Radio Mandatory Zone CAA Safety and Airspace Regulation Group Safety Regulation Group (part of the CAA) Secondary Surveillance Radar Transponder (SSR) Mandatory Zone Unmanned Air Systems Unmanned Air Vehicles UK Airprox Board UK Flight Safety Committee Walney Offshore Extension Wind Farm Wind Turbine Generator Volunteer Gliding Squadron Table 1 Glossary of Terms Glossary 11

12 2 Introduction The presence of the Walney Offshore Extension Wind Farm (WOW03) Wind Farm would affect BAE Systems (BAES) Warton Aerodrome (Warton) flying and Air Traffic Service (ATS) operations, with the most significant impact being the detection of the wind turbines as unwanted clutter by the Warton Primary Surveillance Radar (PSR). 2.1 General DONG Energy (DONG) wish to develop an extension to the existing Walney Wind Farm, referred to as the Walney Offshore Extension Wind Farm (WOW03). The project development site will be located west of the Walney Wind Farms (1 and 2), the operational offshore wind farms in the East Irish Sea to the north of Morecambe Bay, approximately 35 kilometres (km) (18.9 Nautical Miles (NM)) northwest of Fleetwood and Blackpool coast, and 31 km (16.7 NM) from the Isle of Man. DONG is the sponsor for the proposed airspace change herein detailed. The presence of the WOW03 Wind Farm would affect BAE Systems (BAES) Warton Aerodrome (Warton) flying and Air Traffic Service (ATS) operations, and potentially BAES operations at Barrow/Walney Island Aerodrome; thereby requiring a change to the arrangements and procedures in the immediate airspace surrounding the Wind Farms. The current Walney, Ormonde and Barrow Wind Farms do not affect Warton operations and the under construction West of Duddon Sands Wind Farm is not expected to do so as the maximum tip height of the associated WTGs are not within the Warton Primary Surveillance Radar (PSR) Line of Sight (LoS). DONG has engaged Osprey Consulting Services Ltd (Osprey) to project manage the Airspace Change Process on their behalf. The most significant impact on the Warton (PSR) and its operational environment from wind turbines is the risk of wind turbine generated radar returns causing false target generation and track seduction. False or seduced tracks (which in many cases are indiscernible from real tracks) may cause disruption by forcing Air Traffic Controllers to take action in order to maintain radar separation in accordance with standards mandated by the CAA when providing an Air Traffic Service Outside Controlled Airspace (ATSOCAS 1 ). Any loss of radar performance in this area along with any misleading or unnecessarily distracting displayed radar information have the potential to erode levels of safety. Loss in the detection capabilities of the radar and generation of false or seduced tracks in the area of WOW03, could limit the ability of Warton ATC to discharge their 1 Air Traffic Services Outside Controlled Airspace (ATSOCAS) are provided by a variety of air traffic units and used by a wide variety of users from General Aviation to commercial flights and military aircraft. Airspace & Safety Initiative website. Introduction 12

13 responsibilities when providing ATSOCAS within a significant section of the East Irish Sea. When providing a Deconfliction Service (DS), Warton ATC endeavours to provide 5 NM lateral separation between unknown radar returns. Therefore, services would be downgraded, reduced or terminated within 5 NM of the boundary of the Wind Farm, effectively rendering a significant section of the complex airspace operated by Warton as unusable to test and evaluation aircraft requiring a DS. The airspace within the vicinity of the proposed site comprises the N864 Class A airway (Flight Level (FL)55 - FL195) activated at weekends and Public Holidays, Temporary Reserved Area TRA004 (FL195 FL245) Class C airspace, and a Class F Advisory Route (ADR) W2D 2 (FL 55 - FL 185) to the south. With the additional presence of the D406/D406C Danger Areas, Area 13 Air-to-Air Refuelling Area (AARA13), the Warton Supersonic Tracks and the test flights in the Irish Sea Class G airspace, any significant reduction in the airspace available for the manoeuvre of critical flight test activities would be considered unacceptable. 2.2 Purpose and Scope This document has been prepared by Osprey to present the outline intentions of DONG to inform the Framework Briefing to be held at Safety and Airspace Regulation Group (SARG) on 6 th June 2014, in accordance with CAP 725, Airspace Change Process Guidance Document [Ref 1] Stage Document Structure This document, divided into nine main sections and five Annexes, is outlined below for convenience: Section 1 provides a glossary; Section 2, this section, introduces the document; Section 3 details the Background and Justification for the proposed change; Section 4 provides an assessment of the technical mitigation options available; Section 5 describes of the development of the proposed Transponder Mandatory Zone (TMZ); Section 6 gives an initial assessment of the impacts of the proposed change on Airspace Use; Section 7 details the Environmental Aims and Assumptions and Economic Implications; Section 8 provides an outline Consultation Plan; and Section 9 provides a list of references. There are four Annexes: Annex A1 provides an overview of the aircraft types operating from Warton Airfield; 2 This will be removed as a result of the Replacement of Class F Airspace In UK Flight Information Region Consultation Report, 17 April Introduction 13

14 Annex A2 illustrates the Liverpool Bay, Morecambe Bay and BAES Warton airspace; Annex A3 provides the co-ordinates of the proposed TMZ; Annex A4 outlines the WOW03 Airspace Change project plan; and Annex A5 lists the Consultees identified to date. Introduction 14

15 3 Background and Justification DONG, the Defence Infrastructure Organisation (DIO) and Warton Operations personnel believe that the establishment of a Transponder Mandatory Zone (TMZ) would be an operationally acceptable mitigation and aligned with the timescales for the wind farm development. 3.1 Overview The extension of the existing Walney Wind Farm will have potential impacts on Warton flying, and civilian and military ATS operations. DONG, the Defence Infrastructure Organisation (DIO) and Warton Operations personnel believe that the establishment of a TMZ around the existing Walney 1 and 2, Ormonde and Barrow, the under construction West of Duddon Sands and the proposed WOW03 Wind Farms would be an operationally acceptable mitigation and aligned with the timescales for the Wind Farm development. The proposed solution is a combination of Warton PSR suppression of the WTGs returns and TMZ implementation. The appropriate safety management processes will be completed prior to the introduction of any operational change, ensuring there are no issues that could prevent a safe implementation and thus safety levels will be closely monitored and maintained. 3.2 Background A range of military and civilian aircraft operates from the airfield at Warton; the aircraft types, together with a brief description of the flying tasks associated with each type, are included in Annex A1. The airfield carries out, on average, around 1,000 aircraft movements per month in support of the following operational tasks: Flight development and test activities, predominantly on Typhoon, Tornado and Hawk aircraft, which can include civilian test support aircraft operations; Production test flying of brand new Typhoon (and soon to be Hawk) aircraft that are manufactured on site; Daily commercial passenger flying operations; Military and civilian transport operations; National Police Helicopter operations; and Flying training activity on civilian and military aircraft. Warton Air Traffic Control (ATC) provides aerodrome control and approach control services to a wide range of commercial, general aviation and military aircraft in the airspace over the Irish Sea and near Warton. In addition to these standard airfield air traffic tasks, Warton ATC provides a dedicated specialist service to aircraft conducting test and development flights within a 120 NM radius of Warton, and a Lower Airspace Radar Service (LARS) to local air traffic. Background and Justification 15

16 The Warton Advisory Radio Area (ARA) has been notified as specific airspace for flight test operations under Warton control. The standard air traffic services, the LARS, the dedicated test service and Warton ARA combine to provide the required enhanced levels of safety to operate this mix of aircraft efficiently and effectively in the local operating areas. Warton ATC operates under regulatory oversight of both the Military Aviation Authority (MAA) and the Civil Aviation Authority (CAA) Test Flying Warton s coastal location adjacent to extensive Controlled Airspace (CAS) and uncontrolled airspace, makes it an ideal site for testing, research and development with state of the art flight test facilities. The MOD and other export customers rely on this operation for the delivery of high specification military capability e.g. in support of front line military aviation operations. The fast jet military aircraft conducting test and development sorties operate in accordance with predetermined schedules to ensure that appropriate test data is gathered. Test aircrew rely on Warton ATC to provide a mixture of air traffic services Commercial Passenger Operations Warton ATC provides an approach control service to both the outbound and inbound daily shuttle services to Farnborough, RAF Marham, RAF Coningsby and other customer UK locations. In addition, departures and arrivals to Munich operate three times a week. Warton ATC also provides an approach control service to Barrow/Walney Island, which operates aircraft twice a day to Farnborough and twice a day to Bristol National Police Helicopter The National Police Helicopter Service operates a helicopter from a helipad on the south side of the airfield. This high priority operation typically requires a low-level transit in any direction (surface to 1,500 ft typically) from the airfield to the area of interest Warton Air Traffic Services (ATS) The airspace around Warton is of medium complexity. Warton ATC is responsible for providing services to aircraft departing and arriving from Warton, as well as local air traffic and military aircraft involved in complex test and development flights. Central to these tasks is the provision of ATSOCAS provided to those aircraft flying outside controlled, generally Class G airspace 3. Warton ATC provides ATSOCAS to aircraft departing, arriving and transiting through the area (within 40 NM radius from Warton Aerodrome under LARS provision) as well as test and development aircraft undertaking test flights within a 120 NM radius. 3 Class G is uncontrolled airspace in that any aircraft may use the airspace under The Rules of the Air and although an air traffic service may be available it is not mandated - CAA website. Background and Justification 16

17 3.2.5 Provision of an Approach Control Service Warton ATC in accordance with CAP 393, The Air Navigation Order (ANO) [Ref 2] provides an approach control service 4. Warton is also the approach control provider for Barrow/Walney Island and has a Letter of Agreement (LoA) with Blackpool International Airport (BA) 5. All three airfields lie in Class G airspace, therefore all air traffic services to these airfields is conducted in accordance with ATSOCAS Lower Airspace Radar Service (LARS) Warton ATC provides a Lower Airspace Radar Service (LARS) with the purpose of ensuring participating pilots are aware of other nearby aircraft and/or flying activities and enhancing flight safety in the area. This service is available to any aircraft operating in uncontrolled airspace, from ground level up to FL100, within a 40 NM radius of Warton (see Annex A2). However, services are often provided under the LARS scheme to aircraft beyond these limits; due to Warton's extended radar capability and the lack of any other LARS providers in the area. LARS is regarded as a very important service which is sponsored by the Department for Transport (DfT) and is determined by the CAA SARG as key to enhancing the levels of safety of the airspace in an area that can be busy with a mixture of aviation activities Warton Advisory Radio Area (ARA) Activities 3.3 Aims Warton ATC is responsible for providing services in the Warton ARA to enhance the safety of aircraft involved in flight test activities and those other aircraft flying through the area. The Warton ARA is notified from 9,500 ft to 19,000 ft where all pilots are advised to take advantage of receiving a service when flying in the area. In addition, the Warton Fillet is a portion of controlled airspace to the south, within airway L70, that is normally Class C (CAS). When required, Warton ATC can request to claw back the Warton Fillet to support test-flying activities. This changes the status of the airspace to Class G (uncontrolled airspace) for a temporary period to permit test flight operations. This allows tactical freedom close to Warton and its associated support equipment, whilst at the same time ensuring no compromise of flight safety by having in place a robust airspace sharing agreement, between the National Air Traffic Service Provider (NATS) and Warton, to deconflict commercial and test flying activities. The overall aim of the Walney Offshore Extension Airspace Change Proposal is to maintain the effectiveness and efficiency of the Class G airspace near the WOW03 Wind Farm and mitigate the impacts of the WTGs on BAES Warton flying and ATS operations. It is envisaged that this will be achieved through the establishment of a TMZ with Warton PSR suppression of WTGs returns. The secondary objective of the mitigation solution is to minimise any known airspace impacts. Consequently, the proposed 4 Air Navigation: The order and the Regulations Part 23 Air Traffic services, Article The LoA with Blackpool International Airport states, If either unit is unable to provide an approach radar service, the other unit may provide vectors towards the final approach to both airfields. Background and Justification 17

18 TMZ design is intended to be sympathetic to existing airspace structure, traffic patterns and local ATC operations. 3.4 Justification There are four principal issues concerning the effects of the WOW03 on Warton operations: Test flying control within the East Irish Sea; Services to aircraft under the LARS scheme when aircraft are operating outside controlled airspace; Services to aircraft within the Warton ARA when aircraft are operating outside controlled airspace; and Approach Control Service. These areas of concern have led to the requirement to mitigate the effects of the WOW03 development Flight Test Operations As described earlier, Warton provides an ATS for test flight operations within the Warton ARA. The Walney Wind Farms lie in the centre of the Class G airspace utilised for Warton test and evaluation operations and aircraft positioning for a test flight, or AARA13, may route directly over the Walney Wind Farms. Loss in the detection capabilities of the radar, and generation of false or seduced tracks in the area of the WOW03 could limit the ability of Warton ATC to discharge their responsibilities when providing ATSOCAS within the Warton ARA. When providing a DS, Warton ATC endeavours to provide 5 NM lateral separation between radar returns. Therefore, services would be reduced or terminated within 5 NM of the boundary of the wind farm, effectively reducing the volume of airspace available in an already complex operating environment; this would represent a significant reduction in the size of the Warton ARA airspace available for critical flight test activities LARS Provision As stated earlier, Warton ATC is responsible for providing pilots with ATSOCAS in this vertically constrained Class G airspace directly above the proposed development; this includes those arriving/departing from Warton, BA and Barrow/ Walney Island, as well as those military and civil aircraft transiting the area. A recent LARS review by DfT recognised Warton s key role in being a provider of LARS in the northwest of England. It would be necessary to reduce or terminate the service near the Wind Farm if the radar returns from the WTGs were not mitigated Approach Control Service Warton ATC provides an Approach Control Service to aircraft operating to and from Warton, Barrow/Walney Island and BA. All three aerodromes lie outside CAS and when aircraft in receipt of a DS are operating outside CAS near the WOW03 Wind Farm, Warton ATC must endeavour to provide 5 NM separation between traffic, therefore services would be downgraded, reduced or terminated within 5 NM of the boundary of the Wind Farm in the presence of WTG clutter. Background and Justification 18

19 4 Options Considered Warton s preferred solution is to establish a TMZ, with associated suppression of PSR returns within the boundary of the Wind Farms, around the operational, under construction and extension wind farms within the Warton LARS provision times. 4.1 Overview In developing the plans to resolve the issues detailed in Section 2, DONG has considered a variety of options to determine how best to meet the needs of BAES Warton as well as other aviation and non-aviation stakeholders. The most significant impact on the Warton radar and its operational environment from WTGs is the risk of wind turbine generated radar returns causing false target generation and track seduction. The following range of design options was considered: Do nothing; Implement a PSR solution; Implement a Radio Mandatory Zone (RMZ); Conduct Secondary Surveillance Radar (SSR) only operations; Implement PSR blanking or a Non-Automatic Initiation Zone (NAIZ) only; or Implement a TMZ with associated SSR-only operations and PSR suppression of returns. Warton deemed the latter option to be the most feasible for the continued efficient provision of ATS by Warton. The other options were not considered to provide sufficient mitigation, and could potentially have negative effects on the environment through greater overland routing, greater noise exposure by communities and increased emissions. Details of each of the design options considered are provided in the sections below. 4.2 Option 0 Do Nothing In the event that no mitigating actions are taken for WOW03, it is likely that this would impact the PSR service at Warton in the ways described below. Wind turbines located within PSR coverage can reduce the ability of the radar to detect aircraft, and ATC to differentiate between a wind turbine return and a radar return from an aircraft. The following effects have been well documented in CAP 764 (CAA Policy and Guidelines on Wind Turbines) [Ref 3]: Wind turbine generated returns leading to false target generation and track seduction; Loss of receiver sensitivity; Options Considered 19

20 Plot extractor/filter memory overload; Presenting an obstruction (shadow); and Receiver saturation. Each of these effects reduces the effectiveness of radar in detecting targets, which can result in misidentification of aircraft, temporary loss of track position and identity and the generation of false radar returns. Any reduction in radar performance and the consequential loss of situational awareness will result in, as a minimum, a less efficient use of the airspace. If mitigation is not introduced, substantial changes would need to take place to the way in which Warton ATC handles traffic near the WOW03 Wind Farm, perhaps leading to greater overland routing, a greater noise exposure by communities, and greater fuel burn, NO 2 and CO 2 emissions through extended routing around the wind turbine clutter. This option has been rejected as DONG and Warton have agreed that mitigation is required to minimise the impact of WOW03 on Warton operations. 4.3 Option 1 A PSR Solution Warton operates a Selex ES ATCR-44 ATC PSR, which is complimented by a comounted Mode S SSR, and SSR data from NATS radars at Clee Hill and Lowther Hill. DONG and Warton have held discussions with Selex ES, the PSR Design Authority, to investigate if there are approved methods in which the PSR could be modified to enable Warton to continue to provide an ATS using the PSR in the region of the WOW03 WTGs. Due to the large number of wind turbines planned for the Extension, simple radar modifications to provide mitigation are not possible with the existing technology. Mitigation to the PSR would therefore involve a gap filler radar to be integrated alongside the existing PSR system, which will be a lengthy exercise. DONG require certainty of the mitigation in order to reach Financial Close on the WOW03 project in November 2015, and the timescales around definition, selection and implementation of a technical PSR solution do not meet these timescales. 4.4 Option 2 Radio Mandatory Zone (RMZ) A Radio Mandatory Zone (RMZ) would require aircraft to be in two-way communication with ATC and provide information pertinent to the flight prior to entering the designated airspace and aircraft without a radio would not be granted free access in Class G airspace as they have now. Although ATC would be able to provide some level of service to traffic in the area, it would not prevent WTG radar returns from being displayed on the radar display, with the effect of requiring a limited service provision as outlined previously. An RMZ might also reduce the effectiveness of Airborne Collision Avoidance Systems (ACAS) in the zone, as access will be feasible by aircraft without a SSR transponder requirement upon which ACAS relies. Furthermore, Warton ATC would be denied accurate aircraft position information as well as identity and altitude. This operational mitigation does not go far enough to reduce the effects of WTG tracks on Warton ATC displays. Warton has rejected this option as it provides insufficient mitigation. Options Considered 20

21 4.5 Option 3 Secondary Surveillance Radar-Only Secondary Surveillance Radar (SSR) is a co-operative surveillance system that relies on the aircraft being equipped with a transponder. The target aircraft's transponder responds to interrogation by the ground station by transmitting a coded reply signal. The sole reliance and use of this surveillance technique, without appropriate airspace use rules in place, is not approved in the UK due to busy approach environments. However, due to the area of the existing Walney Wind Farms (Walney 1 and 2), Ormonde and Barrow, the under construction West of Duddon Sands and the proposed WOW03 Wind Farms, it may be justifiable to use SSR-only to maintain the identity of an aircraft as it transits through the WTG development. It should be noted that the circumstances when SSR may be used alone in the provision of ATS are limited. The International Civil Aviation Organization 6 (ICAO) Procedures for Air Navigation Services Air Traffic Management (PANS-ATM) states at Section 8, paragraph 8.1.9: SSR systems, especially those utilizing monopulse technique or having Mode S capability, may be used alone, including in the provision of separation between aircraft, provided: a) the carriage of SSR transponders is mandatory within the area; and b) identification is established and maintained. For the UK, the requirement is outlined in MATS Part 1, Chapter 3, paragraph 10.5 as follows: 10.5 Use of SSR alone Provided the pilots are made aware of the limitations of the service, SSR may be used to provide horizontal separation in the following circumstances: a) When approved by the CAA; b) To overcome temporary deficiencies within PSR cover, such as fading or clutter, the SSR return only of one aircraft may be used to provide separation from the PSR or SSR return of another aircraft provided the PSR and SSR situation displays are correctly aligned. However, a permanent large area of clutter, such as that generated by a wind farm, is not considered to be a temporary deficiency in PSR cover. Thus, the principle requirement would be for CAA approval that, in turn, is dependent on fulfilling the ICAO requirement above. 4.6 Option 4 Primary Surveillance Radar Blanking or NAIZ Only PSR Blanking involves the deliberate masking of fixed areas on the radar display. This ensures that clutter caused by a wind turbine development is not presented to the controller. 6 ICAO outlines the principles for airspace protection and procedure design to which all ICAO signatory states must adhere. Options Considered 21

22 The potential drawback of this option is that in addition to wind turbine clutter, primary radar returns from legitimate aircraft are also blanked and therefore not presented to the air traffic controller. Some plot extracted PSR systems 7 have the ability to create NAIZ, which are defined zones within which plot extracted tracks are prevented from initiating, whilst mature tracks are maintained and updated. NAIZ placed over the location of a wind turbine development ensures that turbine blades do not create false tracks, but established aircraft tracks entering the location continue to be updated. A NAIZ in isolation would not remove the risk of wind turbine generated radar returns causing radar track seduction, as 'alternative' plots, available to sustain the deviated path, will not be wholly removed. This option has been rejected by Warton as it provides insufficient mitigation. 4.7 Option 5 A TMZ with associated PSR Suppression Techniques A TMZ is airspace of defined dimensions wherein aircraft wishing to enter or fly within the defined area, will be required to have and operate SSR equipment or receive authorisation (clearance) to enter, via radio, from the TMZ Controlling Authority. The concept of Transponder Mandatory Airspace, in the form of a TMZ, has been developed by the CAA to cater for overriding safety reasons where the airspace classification would not normally require aircraft to carry a transponder. This SSR equipment must include a pressure altitude reporting transponder capable of operating in Mode A and Mode C and have the capability and functionality prescribed for Mode S Elementary Surveillance. The proposed establishment of the TMZ is one element of a 3-part Mitigation Package aimed at negating the impact of the clutter from the Walney Offshore Wind Farm WTGs upon the Warton PSR. The three parts are: Element 1: Establishment of a TMZ; Element 2: Authorisation to control SSR-only; and Element 3: Suppression of PSR returns within the boundary of the Wind Farms. The proposed solution provides Warton ATC with assured positional identification and Commercial Air Traffic (CAT) operators with collision avoidance mitigation through the cooperative use of ACAS. It will also maintain current effectiveness and efficiency in the airspace while radar services are provided using SSR data-only in the area of the Walney Wind Farms. 7 Received radar signals are displayed on ATC displays that, in their simplest form, are direct representations of the target's range, bearing and strength (known as video). By utilising advanced Digital Signal Processing techniques some radars analyse signals and provide them in the form of data messages instead (known as plot extraction). Significant difficulties may be encountered when combining information from plot extracted and video radars. Options Considered 22

23 Aircraft flying through the TMZ will be required to be equipped and operate SSR equipment or to have established two-way radio communications with Warton ATC, the TMZ Controlling Authority. The airspace classification of a TMZ would remain unchanged, Class G in this case. Hence, the ATS available within and around the TMZ would continue to be applied according to ATSOCAS through the assured provision of SSR data to the controller. The primary determining features for the TMZ would be: 4.8 Conclusion The location of current WTGs (Walney 1 and 2, Ormonde and Barrow Offshore Wind Farms); The location of WTGs under construction in the West of Duddon Sands Offshore Wind Farm; The location of the development extension WTGs (WOW03); The tracking characteristics of the Warton PSR; The presentation of the TMZ to pilots (i.e. how it is portrayed on the charts); and The proximity to the Barrow/Walney Island Aerodrome Traffic Zone (ATZ) and its published Instrument Flight Procedures (IFPs). Each of the aforementioned options have been considered in depth by DONG and Warton. Warton s preferred solution is to establish a TMZ, with associated suppression of PSR returns within the boundary of the Wind Farms, around the operational, under construction and extension wind farms within the Warton LARS provision times. The development of this option for the configuration of Transponder Mandatory Airspace is detailed in the subsequent Section of this document. Options Considered 23

24 5 Development of the Proposed TMZ The overall aim of the Walney ACP is to maintain airspace efficiency and effectiveness for all users, and mitigate the impacts of the Walney Extension Offshore Wind Farm on Warton flying and ATS operations. 5.1 Overview The CAA, in CAP 725 [Ref 1], lays down extensive regulatory requirements to be applied to the design of the airspace arrangements. However, most of these requirements, such as Instrument Flight Procedure (IFP) containment, are relevant to the development of CAS, which is not the case with this TMZ proposal. The significant regulatory requirements applicable to this proposal are that the: Dimensions of the proposed airspace should be the minimum practicable to meet the safety and operational requirements; and Configuration of the airspace should be as simple as practicable. Thus, the primary matters for consideration in the development of the proposed TMZ are the lateral and vertical dimensions, including alignment with other, pre-existing, airspace boundaries and the impact on: 5.2 Aim Those aircraft wishing to use the airspace which are not and/or cannot be equipped with a transponder; and The operational impact on adjacent Air Traffic Service Units (ATSU) who may not be SSR equipped. A potential drawback of establishing a TMZ is that non-transponding aircraft may choose to take an alternative route in order to bypass the TMZ, resulting in a change in traffic patterns and ATC workload in this area. This would only reasonably occur when the non-transponding aircraft have been unable to establish two-way radio communications with Warton ATC, the TMZ Controlling Authority. The overall aim of the Walney ACP is to maintain airspace efficiency and effectiveness, for all users, and mitigate the impacts of WOW03 on Warton flying and ATS operations. It is envisaged that this will be achieved through the establishment of a TMZ with Warton PSR track suppression within the boundary of the WOW03 Wind Farm. The secondary objective of the mitigation solution is to minimise any known airspace impacts by allowing continuity of a full suite of ATSOCAS provision in the vicinity of the Walney Offshore Wind Farms. Consequently, the proposed TMZ design is intended to be sympathetic to existing airspace structure, traffic patterns and local ATC operational norms. Development of the Proposed TMZ 24

25 5.3 TMZ Boundary Requirements and Operation TMZ Horizontal Buffer Zone It is not possible to remove only the radar returns from the WTGs without also removing wanted radar returns from aircraft. This is why PSR Blanking in isolation is not considered a viable mitigation for the Walney Wind Farms. The objective of establishing the TMZ is not to prevent aircraft from operating near the turbines, but to require that they operate a transponder, or are in two-way radio contact with Warton ATC, when so doing. Notwithstanding, there is always potential for a non-transponder-equipped aircraft to inadvertently enter the TMZ, once in this area, the aircraft radar return would not be presented to the radar controller, and any opportunity to provide separation from other (transponding) aircraft in the area would be lost. In order to assure effective and expeditious ATS provision within and around the TMZ, it is considered that an additional lateral buffer for ATS purposes is necessary to mitigate the potential navigation error that might occur whenever pilots of nontransponding aircraft fly close to the area of PSR return suppression. Such a buffer zone would provide time for ATC to provide avoiding action, if required, to other aircraft close to the boundary of the TMZ. Thus, it is concluded that an additional volume of airspace should be added to the surface footprint of the Wind Farms themselves to cater for TMZ infringements. Figure 1 below illustrates the proposed TMZ in relation to the Walney Offshore Wind Farms in Morecambe Bay. Figure 1 Walney Proposed TMZ including 2 NM Buffer Zone. Reproduced from OS digital map data Crown copyright Development of the Proposed TMZ 25

26 The Warton PSR requires 30 seconds to establish and display an aircraft track (6s per sweep with the track displayed on the 5 th sweep). Considering the worst case scenario, where Class G General Air Traffic (GAT) can travel up to speeds of 250 kts (7.7 km/min or 4 NM/min), the Warton radar would therefore require 2 NM (3.7 km) to create a coherent foreground track. It is therefore logical to implement a 2 NM (3.7 km) lateral buffer zone around the required TMZ over the Wind Farms, in order to ensure that tracks are well initiated and known to ATC as they approach the zone. Due to the proximity of WOW03 Wind Farm to the existing Walney (1 and 2), Ormonde and Barrow, the under construction West of Duddon Sands Offshore Wind Farms, the TMZ would encompass all these wind farms. This would avoid issues with visual confusion from the air, difficulty in navigation chart interpretation and visual depiction on ATC video display screens. TMZ boundary options are shown in Annex 2 and boundary coordinates in Annex 3. By way of comparison to other offshore wind farm mitigations, the TMZs around the London Array and Thanet Offshore Wind Farms, that were administered by Manston ATC, also had buffer zones of 2 NM (3.7 km). 5.4 Vertical Extent of the TMZ It is proposed that the TMZ should extend from sea level up to FL100, since transponder carriage above FL100 is already mandated. The co-ordinates for the corners of the Walney TMZ (with buffer zone) are given in Annex A3, together with the proximity of the TMZ to military and civilian aerodromes. 5.5 Hours of Operation of the TMZ Under normal UK Integrated Aeronautical Information Package (IAIP) arrangements, the operating hours of a particular airspace segment established for ATS purposes are linked to the operating hours of the associated ATS Unit. Hence, DONG and Warton propose that Warton ATC is the TMZ Control Authority and TMZ activation coincides with the Warton LARS hours (Mon-Thu ; Fri Local Time). The information will be captured within the UK IAIP, noting the LARS frequency and timings as well as the boundary of the TMZ. Activation 24/7 is discounted as overly burdensome as 24/7 operation would require the employment of another Controlling Authority (when Warton is not operating). However, Warton propose that exceptions to this are promulgated by Notices to Airmen (NOTAM). 5.6 Implementation Implementation of the TMZ could be on a single implementation date. DONG proposes to detail the TMZ within the Warton entry within the AD2 portion of the UK Mil AIP, in UK IAIP ENR GEN 1.5 (Aircraft Instruments, Equipment and Flight Documents) and ENR 6.1 (Morecambe Bay/Liverpool Bay Gas Field Helicopter Support Flights). This would serve the purpose of formally notifying the TMZ. It is intended to be as flexible as possible in the use of the airspace. The intention would be to maintain records of the Walney TMZ utilisation and purpose along with refusal of access or use; data collation on a monthly basis and reviewed as part of the Post Implementation Review (PIR). Development of the Proposed TMZ 26

27 5.7 Work to Date An indicative plan of activity required to deliver the ACP has been developed, provided at Annex A3. Implementations of the airspace change will coincide with the WOW03 operational date. An outline of the consultation document is being drafted, and will be populated following the receipt of guidance at the Framework Briefing and on completion of the initial draft of the airspace design. Development of the Proposed TMZ 27

28 6 Potential Impact on Airspace Use It is considered that military operations would be unaffected by the TMZ requirements, since in most cases military aircraft operate Mode S compatible SSR transponders. The effect of the TMZ on civilian aerodromes depends entirely upon whether the wind turbines themselves are within the radar horizons of those ATSUs and to some extent as to whether aircraft under its ATS provision are transponder equipped. It is recognised that the majority of locally based light aircraft are, or will be, transponder equipped. Given the ability for conditional access to the TMZ airspace by non-transponder equipped aircraft, it is anticipated that the impact of a TMZ on light GA operations would be minimal. 6.1 Overview Any change to the requirements of mandatory carriage of equipment in a particular airspace, is likely to have an impact on the use of the airspace including a secondary (unintended) impact such as re-routing of traffic in ways that tend to reduce the overall efficiency of the airspace concerned. This Section will explore the anticipated effects of the proposed changes to the airspace under consideration in this study and on airspace users. 6.2 Impact on Military Operations The majority of UK and European-based military aircraft carry and operate SSR transponders, in most cases these are Mode S compatible. The only UK military types that are not transponder equipped are gliders. It is considered that military gliders are unlikely to operate as far offshore as the Walney Wind Farms and so would be unaffected by the TMZ requirements RAF Valley RAF Valley is an RAF station situated on the island of Anglesey in Wales. It provides fast-jet training for pilots using the BAE Systems Hawk. It is also provides training for aircrew involved in Search and Rescue operations, rescuing people from ships in the Irish Sea, from the mountains of nearby Snowdonia and elsewhere. 6.3 Impact on Civilian Aerodromes The effect of the TMZ on other ATSUs depends entirely upon whether the wind turbines themselves are within the radar horizons of those ATSUs and to some extent as to whether aircraft under its ATS provision are transponder equipped Isle of Man Airport (IoMA) IoMA is the main civilian airport on the Isle of Man and is regulated by the IoM Directorate for Civil Aviation (DCA), an arm of the IoM Government (IoMG). It has a DCA Public Use Aerodrome Licence that allows flights for the public transport of Potential Impact on Airspace Use 28

29 passengers (domestic services and scheduled flights to locations across Europe) and for flying instruction. It is located in the south of the island at Ronaldsway near Castletown, 6 NM (11 km) southwest of Douglas, the island's capital. The airport operates scheduled services to the United Kingdom, Ireland and the Channel Islands. Andreas Helicopters operate between the north of the Isle of Man and BA or Harwarden, mainly to the south of the existing Walney Wind Farm and proposed WOW03. ATC operations at IoMA have the potential to be affected by the introduction of the Walney TMZ. IoMA ATC participates with Warton ATC in the coordination of traffic and receives radar handovers from Warton ATC. It is anticipated that the WTG of the WOW03 Wind Farm will be visible to the IoMA PSR Blackpool International Airport (BA) BA on the Fylde coast of Lancashire, is licenced for the public transport of passengers and for flying instruction. Three scheduled airlines operate from the airport, as well as occasional charter holiday flights in the summer months. Helicopter operations serve the offshore oil and gas facilities in the Irish Sea, operated by Bond Offshore Helicopters. BA is also home to the North West Air Ambulance service. There are many companies situated on the airfield which offer flying lessons and training flights. The fixed-wing lessons are usually in Piper or Cessna aircraft and the Robinson family of helicopters used for non-fixed wing lessons. ATC operations at BA have the potential to be affected by the introduction of the Walney TMZ; the close proximity of Morecambe Bay gas facilities means that the TMZ boundaries should be displayed on the BA radar screens Barrow/Walney Island Aerodrome Barrow/Walney Island Aerodrome is located to the north of Walney Island and is owned and operated by BAES. A regular daily weekday transfer flight, typically a Beechcraft King Air B200, is operated between Barrow/Walney Island, Farnborough and Bristol Airports. The Aerodrome is also home to the Lakes Gliding Club, which supports member flying, and glider training activities. ATC operations at Barrow/Walney Island will be affected by the introduction of the TMZ due to the close proximity of the aerodrome to the TMZ boundary Cark Aerodrome Cark Aerodrome is an unlicensed airfield located in Flookburgh, 7 NM (13 km) south of Lake Windermere and is operated by the North West Parachute Centre. The aerodrome welcomes light aircraft on a Prior Permission Required (PPR) basis and does not accept non-radio aircraft. The airfield is home to intensive free fall parachuting, with parachutists free-falling up to 14,500 ft and deploying their parachutes from 2,200 ft down. 6.4 Impact on Light GA operations All aircraft operating on Public Transport flights within UK airspace are required to be equipped with, as a minimum, Mode S Elementary transponders. It can be assumed that the majority of GA aircraft over 5,700 kg MTWA are likely to be transponder equipped on the basis that such aircraft types which can be used for Potential Impact on Airspace Use 29

30 public transport operations are likely to operate from time to time within Class A, C or D CAS. Thus, the predominance of non-transponder equipped aircraft affected by the proposed TMZ is likely to be aircraft of less than 5,700 kg MTWA, which are never operated on Public Transport flights. Whilst not prohibited from operating over water, the majority of pilots of light aircraft prefer to minimise their over-water flight time by using shorter over-water routes; Warton ATC note that the majority of GA operating around the periphery of Morecambe Bay do so along the coastlines applying the Right-Hand Traffic Rule Notwithstanding the transponder mandate within a TMZ, provision exists within the TMZ rules for conditional access by non-equipped aircraft by prior arrangement with the appropriate ATS Unit. Occasionally locally-based (Barrow/Walney Island, BA and IoMA) light aircraft undertake offshore sight-seeing flights which may include the Walney Wind Farms. It is recognised that the majority of locally based light aircraft are, or will be, transponder equipped. Given the ability for conditional access to the TMZ airspace by non-transponder equipped aircraft, it is anticipated that the impact of a TMZ on light GA operations, including glider, microlight and balloon operations, would be minimal. 6.5 Impact on Offshore Helicopter Operations As outlined in Section 6.4 above, aircraft likely to be affected by the proposed TMZ are those with an MTWA of less than 5,700 kg. Offshore helicopter types are categorised into the following MTWA groups: Extra Heavy Twin >20,000kg (e.g. Chinook); Heavy Twin >5,700kg (e.g. Bell 214ST, Super Puma, EC225, S61 and S92); Medium Twin 2,730 to 5,700kg (e.g. Dauphin, EC155, S76 and AW139); and Light Twin <2,730kg (e.g. Bo105) Barton Helicopters Cardinal Helicopter Services are based at City Airport and Heliport, Manchester (formerly known as Barton Aerodrome and City Airport Manchester). Cardinal Helicopter Services provide a helicopter charter service, flying a Sikorsky S76C++, in the northwest of the UK that caters for the private and business community Bond Offshore Helicopters Bond Offshore Helicopters, operating from BA, specialise in providing offshore helicopter transportation services to the North Sea and Irish Sea oil and gas platforms. Bond operations include offshore wind farm and lighthouse maintenance and aerial lifting. Bond also provides commercial Search and Rescue helicopter services from Caernarfon aerodrome for the United Kingdom Maritime and Coastguard Agency. 8 CAP 393. Air Navigation: The Order and the Regulations (ANO). Potential Impact on Airspace Use 30

31 Bond Offshore Helicopters fleet consists of a Eurocopter EC135 and 225, Eurocopter AS332L2 Super Puma Mk2, Eurocopter AS365N3 Dauphin, Agusta Westland AW139 and a Sikorsky S-92. Potential Impact on Airspace Use 31

32 7 Environmental Assumptions and Economic Implication Overall, it is anticipated that the environmental impact of a Walney TMZ will be neutral within the three major categories of noise, fuel burn and local air quality because of the airspace change. Any economic benefit is derived mainly from enabling the wind development to proceed and the avoidance of protracted rerouting of CAT, GAT and military aircraft operating to and from BAES Warton, Barrow/Walney Island Aerodrome, IoMA and BA. 7.1 Overview This section explores how the proposed changes may have an overall effect on the environment in terms of noise pollution, fuel burn and local air quality. It further details what studies are anticipated to be required to analyse the environmental impact of the proposed changes. Wide ranges of studies are detailed within CAP 725 [Ref 1] Appendix B. A specialist company will be engaged to conduct the relevant environmental studies where required. The airspace within which the introduction of the TMZ is proposed lies offshore in Class G airspace. The closest proximity of the TMZ to the mainland is 3 NM (5.6 km). Notwithstanding that the proposed TMZ airspace is not CAS, and no aircraft operations are excluded from it, it is possible nonetheless that some GA operators might elect to route on, or closer to shore to avoid the TMZ requirements rather than routing offshore through the TMZ. As airspace activity in Class G airspace is not routinely monitored, it is not possible to gauge or anticipate those flights that would elect to re-route simply as a consequence of the TMZ, even though a TMZ itself does not inhibit flight operations. However, it is understood that the large majority of transit GAT in the Walney Wind Farms area remain close (within 1 NM or 1.9 km) to the coastline Impact of Noise It is expected that the noise impact immediately after implementation is not likely to be significantly different from the pre-implementation situation Anticipated Level of Fuel Burn/CO 2 Emissions It is recognised that aircraft contribute to carbon dioxide (CO 2 ) emissions and this has an impact on climate change. A responsible approach to airspace planning is to balance the competing demands and ensure that the most direct routes possible are used with optimal aircraft performance as this will minimise fuel burn and emissions and therefore reduce the impact upon climate change. This airspace proposal ensures that efficient routing of aircraft is sustained. Environmental Assumptions and Economic Implication 32

33 The ACP will demonstrate how the design and operation of the airspace will impact on CO 2 emissions, primarily on the basis of fuel burn. The TMZ application will produce a qualitative assessment of any anticipated climate change impacts Anticipated Effect on Local Air Quality CAP 725 [Ref 1], Appendix B, Annex 8 identifies that local air quality at ground level remains largely unaffected by aircraft emissions that take place above 3,000 ft agl, because dispersion reduces concentration levels for these emissions. It is understood that in the context of local air quality, the overall objective under CAP 725 is to determine whether the proposed airspace changes will exceed any statutory air quality standards, and if so, what contribution the airport operations make towards such departures. It is not anticipated that Air Quality Standards will be breached or that an atmospheric dispersion modelling assessment will be required because of the airspace change Environmental Implications Overall, it is anticipated that the environmental impact of a Walney TMZ will be neutral within the three major categories of noise, fuel burn and local air quality as a result of the airspace change. It is not anticipated that the Walney TMZ will reduce the environmental impact of aviation in the subject airspace; however, it is reasonable to expect that the environmental impact of aviation in the subject airspace will not worsen as a result of the change. Both tranquillity and visual intrusion are unlikely to be impacted and, in the worst case, the numbers of those negatively affected are not likely to increase significantly upon implementation. 7.2 Economic Benefit The establishment of the TMZ is a safety requirement to enable radar-based ATS to be sustained near the existing Walney Offshore and proposed WOW03 Wind Farms. Any economic benefit is derived mainly from enabling the wind development to proceed and the avoidance of protracted re-routing of CAT, GAT and military aircraft operating to and from BAES Warton, Barrow/Walney Island Aerodrome, IoMA and BA. Environmental Assumptions and Economic Implication 33

34 8 Consultation Plan The Consultation Document will provide full details of the proposed change, its perceived impact and the measures that DONG and BAES Warton have taken to mitigate those impacts. It will incorporate all the feedback already received from the major aviation stakeholders to demonstrate that the change has not been developed in isolation and that DONG and BAES Warton have considered the local and aviation communities. Full consultation will commence with wide circulation of the electronic Consultation Document to all identified stakeholders in September 2014 on completion of the design process and environmental studies. 8.1 Overview The proposed changes to the airspace over the Walney Offshore Wind Farms and their vicinity, means that a number of stakeholders, both aviation and non-aviation, will be impacted. Consultation is a key area to the success of the Walney ACP and extensive preparation is vital to ensure that all major stakeholders and their concerns are identified and engaged throughout the process. 8.2 Consultation Methods There is no substitution for face-to-face meetings with stakeholders, particularly in the local community, in formulating an effective and open relationship. This is essential in ensuring a full understanding of the stakeholder s needs and the potential impact on the surrounding area. Consequently, prior to the preparation of the Consultation Document, it is intended to conduct meetings with the following major stakeholders: BAES Warton Local Consultation Working Groups; Barrow/Walney Island Aerodrome; Blackpool International Airport (BA); Isle of Man Airport (IoMA); Bond Offshore Helicopters (helicopter operators to the Liverpool and Morecambe Bay gas fields); Barton Helicopters; and Cark aerodrome. Although most of these organisations will have been contacted during the initial requirements capture phase, the purpose of these meetings is to present the detail that will be incorporated into the Consultation Document to ensure there are no surprises for stakeholders when it comes to formal comment. The Consultation Document will provide full details of the proposed change, the rationale behind it, the perceived impact the change is likely to have and the measures that DONG and Warton have taken to mitigate those impacts. It will Consultation Plan 34

35 incorporate all the feedback already received from the major aviation stakeholders to demonstrate that the change has not been developed in isolation and that DONG and Warton have considered the local and aviation communities. The Consultation Document will be available publicly, so must be cognisant of local sensitivities. The Consultation Document will be published through the most appropriate means for the local area, in conjunction with any advice and guidance the DONG and Warton Media and Communications Officers will provide. The most effective consultation method for targeting public viewing will be through publication on a dedicated webpage on the DONG website, with a further option for consultees to submit their responses through a dedicated address. Meticulous records of issues raised of the consultation document, reminder letters/ s and receipt of responses will be made throughout the 12-week consultation period. All objections will be carefully considered in conjunction with Warton staff and a response provided to the consultee. Where an objection is received without an explanation of the basis for the objection, Osprey will contact the consultee for further detail in order to provide an informed response. The Consultation Record Sheet provided within CAP 725 [Ref 1] Appendix 3 will be used. Once an appropriate number of responses have been received, analysis will be conducted to identify if there are any key themes emerging; it must be shown that objections or suggestions from consultees have been considered and, if discounted, justifications provided. On closure of the Consultation phase, a report will be produced that addresses key themes that arose and how Warton will incorporate those concerns into their plans. The Consultation Feedback Report will be published on the DONG website Aviation Stakeholders Following engagement with local aviation stakeholders and finalisation of the airspace design, the DONG website will host the consultation document and a letter or issued to all aviation stakeholders. This letter will give a broad outline of the issues and direct aviation stakeholders to the website. Ahead of the consultation document being posted on the DONG website, a programme of local aviation stakeholder meetings will take place to provide details of the proposed changes. It is intended that a dedicated address for open responses be provided; with the provision of the consultation document where requested Non-Aviation Stakeholders Local councils along the Morecambe Bay and Walney Island coast will receive an electronic copy of the Consultation Document and will be encouraged to submit responses on-line, but details of relevant addresses for hard copy submission of responses will also be made available. On-line responses will be addressed through the DONG website. 8.3 Consultation Programme Local aviation stakeholders will be engaged at an early stage during the design process. Full consultation will commence with wide circulation of the electronic Consultation Document to all identified stakeholders in September 2014 on completion of the design process and environmental studies. Annex A5 lists current identified consultees. The current programme plan provides approximately three Consultation Plan 35

36 months for the consultation process, scheduled for completion in December This allows the minimum of twelve weeks required for formal consultation, and provides scope for any unforeseen delays at the start, or significant issues that arise during the process. Consultation Plan 36

37 9 References Reference Name Origin 1 CAP 725 CAA Guidance on the Application of the Airspace Change Process Third Edition (corrected) April CAP 393 Air Navigation: The Order and the Regulations Third Edition (incorporating amendments up to 1/2014) February CAP 764 CAA Policy and Guidelines on Wind Turbines Fifth Edition June 2013 CAA ISBN CAA ISBN CAA ISBN Table 2 Table of References. References 37

38 A1 Aircraft Operated from Warton A1.1 Typhoon The Typhoon is a very sophisticated, high performance, twin engine, supersonic, multi role combat aircraft designed for both air to air and air to ground roles. It is equipped with an ejection seat. There is a significant amount of production and development flight test activity for both the RAF and export customers. A1.2 Tornado The Tornado is a twin engine fast jet combat aircraft, fitted with an ejection seat, capable of Air Interdiction and Close Air Support. BAES conduct flight tests on Royal Saudi Air Force Tornados flown from Warton. Development flight test is likely for the foreseeable future. A1.3 Hawk The Hawk is a single engine fast jet advanced training aircraft, fitted with an ejection seat, which is operated by many countries world-wide. The RAF have upgraded to the Hawk Mk128 standard, which dominates the testing activity on this aircraft at Warton. Hawk production has begun at Warton for the Royal Saudi Air Force requiring significant on-going development and production flight test activities for the foreseeable future. In addition, there is likely to be future additional Hawk customer pilot training activities at Warton, based on export successes. A1.4 Jetstream 31 A modified Jetstream 31 is operated from Warton conducting experimental flight test activities in support of Unmanned Air Vehicle (UAV) research. A1.5 Unmanned Air Systems UASs, also referred to as Remotely Piloted Air Vehicles, are currently being designed, built and operated by BAES at other locations. BAES aim to conduct regular Unmanned Air Systems (UAS) flying at Warton in the future. A1.6 Commercial Passenger Operations Daily shuttle services operate for BAES employees and key customers from Warton to BAES and customer UK locations: return services to Farnborough, RAF Marham and RAF Coningsby run daily and a service to Munich operates twice a week. The aircraft involved are the BAe146 (four engine passenger jet), the Embraer 145 (twin engine passenger jet) and the Jetstream 41 (twin turbo prop aircraft). Warton Based Aircraft 38

39 A2 Morecombe Bay Airspace Diagram A2.1 Morecombe Bay Offshore Area The proposed TMZ is bounded in green on Figure 1. Figure 2 Morecambe Bay Airspace and TMZ. Reproduced from CAA digital map data Crown copyright UK IAIP ENR. Optional TMZ is bounded in green on Figure 2 and adjusted to provide greater clearance from the Barrow/Walney Island ATZ. Figure 3 Morecambe Bay Airspace and TMZ Option. Reproduced from CAA digital map data Crown copyright UK IAIP ENR. Airspace Diagrams 39

40 A3 Proposed TMZ Co-ordinates A3.1 Proposed TMZ Co-ordinates The co-ordinates for the fifteen corners of the Walney Offshore Wind Farm TMZ (with buffer zone) are given in Table 3 below. Point Latitude WGS84 Longitude 1 N W N W N W N W N W N W N W N W N W N W N W N W N W N W N W Table 3 Walney TMZ Co-ordinates. The proximity of the proposed TMZ to local military and civilian aerodromes is given in Table 4 below. Aerodrome Proximity of TMZ (NM) Proximity of TMZ (km) RAF Valley IoMA Proposed TMZ Co-ordinates 40

41 BAE Systems Warton Cark Aerodrome Blackpool International Airport Barrow/Walney Island Aerodrome Table 4 TMZ Proximity to Military and Civilian Aerodromes. Proposed TMZ Co-ordinates 41

42 A4 Walney Offshore Airspace Change Project Plan Walney Offshore Airspace Change Project Plan 42

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