Review of the designation of Class C controlled airspace in the Mount Cook area - Consultation November 2013 Civil Aviation Authority
Table of Contents Background... 1 Final decision... 1 The introduction of controlled airspace above FL245... 2 Qantas petition... 2 National Airspace Policy... 2 Queenstown and Christchurch flights... 4 Consultation list... 4 Submissions... 5 Further information... 5 Appendix A... 6 14 November 2013 i
Background In May 2012 an application was received for the designation of upper level controlled airspace in the area above Mount Cook, Central Otago to enable international jet passenger air transport over-flights to access airspace currently designated as uncontrolled Class G. When appraising the application, the Civil Aviation Authority (CAA) decided that a complete review of the airspace was needed as this area had not been considered in the previous redesign of the southern airspace to align with new performance based navigation (PBN) procedures to be introduced in November 2012. The review was conducted under the requirements of Civil Aviation Rule 71.11 that each airspace designation and classification be reviewed at least every five years to verify the continuing need for the airspace designation or classification. Prior to consultation with industry, input to the review was sought from the air traffic services provider, Airways Corporation of New Zealand Ltd (Airways). The air traffic control (ATC) unit responsible for the airspace, Enroute Area Sector, advised that they had been intending to request that this airspace be designated an upper level control area for safety and efficiency reasons as it would enable better air traffic management with more direct routing, weather avoidance and traffic diversion opportunities available for both domestic and international air transport operations. Consultation was then undertaken with industry based on a proposed lower level of controlled airspace of flight level (FL) 175 (approximately altitude 17,500 ft). The final consultation document Southern Airspace Review proposal for the designation of Class C controlled airspace in the Mt Cook area (DW1255036-0) was sent out to industry at the end of November 2012 with a submission cut-off date of 31 January 2013. A copy of this document is available on the Civil Aviation Authority website - http://www.caa.govt.nz/airspace/airspace_review_22nov2012.pdf. There were 72 submissions received, of which 70 from the gliding sector were opposed to the proposal. Airways and Qantas supported the proposal. Final decision Based on the information provided in the submissions received CAA designated an upper control area, NZA939, with a lower limit of FL245 effective from 14 November 2013. The information provided in the submissions identified that amending the lower level to FL245 would minimise the impact on the majority of visual flight rules (VFR) operations, while enabling access for upper level air transport operations which is currently excluded from using this airspace. From the submissions received, only 11 stated that they used FL245 and above. A letter was sent to Gliding New Zealand on 25 July 2013 formally advising the decision to designate NZA939. On 29 August 2013, Nigel Davy, President Gliding New Zealand, requested that the Director review the decision. As a result, the Director has decided to consult further with industry on the proposed introduction of controlled airspace with a lower level of FL245 to ensure all information is considered. 14 November 2013 1
Whilst this consultation is being undertaken, the designation of the airspace above Mount Cook which was to be effective on 14 November 2013 has been revoked by NOTAM. The introduction of controlled airspace above FL245 Controlled airspace is designed to protect instrument flight routes and procedures. Most air transport operations do not operate within uncontrolled (e.g. Class G) airspace for safety reasons. Currently this airspace cannot be used for air transport operations and is not available to ATC for ensuring safe and efficient flight. In controlled airspace, safe operations are assured where ATC procedures prevent collisions between aircraft and enhance traffic flow, as well as approval of operational requests such as track deviation around weather, preferred routing for track shortening or fuel economy and environmental reasons. Controlled airspace does not prevent access, but an ATC clearance is required before entering. New aircraft navigation systems have allowed the introduction of routes that are not determined by ground based navigation aids. Qantas petition Qantas petitioned for designation of controlled airspace to facilitate more efficient flexitracking of flights between Australia and South America. Data provided from Airways shows that there are over 600 flights per year by all operators not just Qantas that fly routes between Australia and South America which could use this airspace or transit the area adjacent to Mount Cook. Optimal tracks are not necessarily related to the shortest distance over the ground (great circle track). Wind component plays a large role in determining the shortest flight time and hence fuel burn. In many cases this can mean that the Sydney - Santiago route sector results in a longer ground track-distance. Mount Cook airspace is more than one degree of latitude (approximately 75 NM) in length from north to south. Should the optimum track route through the middle of this airspace, there is potential for a required 30-35 NM deviation to the north or south (defeating the purpose of optimal routing and reduced fuel burn). The image attached in Appendix A provided by Qantas shows this variation in optimum routes across a monthly statistical wind data analysis. Approximately 20% of flights on the Sydney Santiago Sydney services track through the Mount Cook airspace. Of those flights, flight plan data shows an estimated 300 kg increase in fuel burn is required to divert either side. For a B747, every one minute of flight time saved equates to approximately 200 kg of fuel and associated CO 2 emissions. The current Qantas Sydney-Santiago schedule of three return services per week has a potential fuel saving of approximately 62,000 kg per annum with flow-on benefits to the environment and the economy. National Airspace Policy The principles and desired attributes of the National Airspace Policy were taken into account when considering this proposal. 14 November 2013 2
Designating a control area supports the National Airspace policy principles of: Safety air transport operations would receive the protection of controlled airspace for operational reasons including traffic separation from other aircraft and bad weather diversion. Compatibility VFR flights rarely operate in upper airspace levels this is normally the domain of air transport operations that require separation, flexibility of routing for weather diversion, air traffic flow management and track shortening where possible. Accordingly, most states establish controlled airspace at such levels. New Zealand upper level airspace should be predictable and consistent. Having uncontrolled airspace above FL245 in the New Zealand flight information region is not consistent with the other upper level airspace in the New Zealand or Auckland Oceanic flight information regions. Accessibility air transport jet aircraft are currently restricted from operating within an upper level portion of New Zealand domestic airspace because ATC is not provided. Gliders would continue to be able to access this airspace if it were controlled. Gliders do not operate at night, nor when the conditions are unfavourable, and specialised oxygen equipment is generally required for flight above 25,000 ft. A conservative estimate is that these factors restrict glider use of this upper level airspace to no more than 30 per cent of the time the airspace above FL245 would be used by gliders. Jet air transport operations face no such restrictions. The designation of this upper level airspace as a control area also satisfies the desired attributes of the New Zealand airspace system of the National Airspace policy: Efficiency air transport aircraft would be able to fly more direct or favourable routes using advanced navigation technologies on board the aircraft. Environmentally responsible air transport aircraft would be able to fly the most efficient route to save fuel and reduce emissions. Interoperable designating this airspace as controlled Class C will mean that there is controlled airspace over the majority of New Zealand at FL245 and over the entire country above FL285. This is consistent with conventional international practice and accepted airspace design principles and results in upper airspace being consistent and predictable for all operators. Over Australia all upper level airspace is controlled Class A above FL245, all of the airspace over the United Kingdom is controlled Class A above FL180, all of the airspace over Europe is controlled above FL190 and similarly over the United States all airspace above FL180 is controlled Class A. In regard to Mount Cook the airspace would be designated Class C and would be accessible to appropriately equipped gliders after receiving an ATC clearance. Both the New Zealand Airspace Policy and the PBN Implementation Plan identify the use of new technology for safety, efficiency and environmental improvements. As identified by Airways and Qantas, the designation of an upper level control area in the Mt Cook airspace will maximise the advantages of PBN technologies in this airspace for air transport 14 November 2013 3
operations not only between South America and Australia but also to and from Queenstown and Christchurch airports. Queenstown and Christchurch flights Flights from Christchurch to Melbourne would be able to track direct to instrument waypoint LIBLA when winds are favourable, rather than the dog-leg via MOLGI currently required to remain within controlled airspace. There are normally four flights per day to Melbourne by different operators. Christchurch to Singapore flights also use LIBLA to optimise flexitracking. A Christchurch-Perth return service will begin in December 2013 which will likely be tracking south of the Christchurch-Melbourne route. The proposed controlled airspace would allow for the most direct routing which is over the Mount Cook area. Departures from Queenstown to Auckland off runway 23 would be able to track more directly once clear of terrain (above FL160) to waypoints further along the track. The introduction of improved southern surveillance in December 2013 will enable better use of these tracks and direct routing under radar control for weather avoidance, tactical air traffic management and efficiency. Expected growth of international operations at Christchurch by foreign carriers and on domestic routes between Queenstown and northern airports will further increase the demand for using this airspace. In the current aviation system environment, operators aim to exploit the safety and efficiency of PBN and of flexible routes, and to receive an ATC service to provide appropriate separations and tactical vectoring of aircraft for safety. Consultation list The following organisations have been sent this consultation document. - Air New Zealand Group - Airways Corporation of New Zealand - Gliding New Zealand - Glide Omarama - Jetconnect Ltd - Jetstar Airways Pty Limited - New Zealand Airline Pilots Association - Qantas Airways Ltd - Queenstown and Milford User Group - Royal New Zealand Air Force 14 November 2013 4
- South Canterbury User Group - Westland/Mt Cook User Group - Wanaka Airport User Group Submissions As stated above, the Director has agreed to consult further with industry regarding the proposal to designate Class C controlled airspace above FL245 in the Mount Cook area as described in the previous consultation document. This document forms part of the consultation process. Submissions are sought from any interested person, organisation or representative group to provide further information relevant to this proposal. Submissions are accepted either electronically or via mail. Please address submissions to: Group Executive Officer Aviation Infrastructure and Personnel Civil Aviation Authority of New Zealand PO Box 3555 Wellington 6140 Fax: 04-569-2024 Email: dianne.parker@caa.govt.nz Reference Mount Cook Controlled Airspace Review Closing date for submissions is Friday 6 December 2013. Further information For further information contact: Paula Moore Aeronautical Services Officer Air Traffic Services (Airspace) Civil Aviation Authority of New Zealand P O Box 3555 Wellington 6140 Phone: (DDI) 04 560 9525 Email: paula.moore@caa.govt.nz S-D180-05/5 (DW1277404-0) 14 November 2013 5
Appendix A Variation in optimum routes across a monthly statistical wind data analysis Sydney Santiago Sydney flights Blue lines = SCL-SYD Pink lines = SYD-SCL Yellow lines = Mt Cook Airspace Black line = Great circle track between SYD and SCL 14 November 2013 6