Page 1 of 11 Airspace Change Proposal - Environmental Assessment Version: 1.0/ 2016 Title of Airspace Change Proposal Change Sponsor Isle of Man/Antrim Systemisation (Revised ATS route structure over the Irish Sea) NATS SARG Project Leader Case Study commencement date 25/05/2017 Case Study report as at 30/06/2017 File Reference Instructions In providing a response for each question, please ensure that the Status column is completed using the following options: Yes No Partially N/A To aid the SARG Project Leader s efficient Project Management it may be useful that each question is also highlighted accordingly to illustrate what is: resolved Green not resolved Amber not compliant Red as part of the AR Project Leader s efficient project management.
Page 2 of 11 Airspace Change Proposal - Environmental Assessment Version: 1.0/ 2016 1. Introduction This report describes the environmental considerations relevant to the proposed Isle of Man (IoM)/Antrim Systemisation. The Airspace Change Proposal has been submitted by NATS, as part of its obligation to update airspace infrastructure. As part of the ACP process, the sponsor has submitted relevant documents so the environmental benefits of the proposal can be assessed. Revised ATS route structure over the Irish Sea, Issue 1.0, dated 29 th March 2017, is the main supporting document (hereafter Main document ), where all the aspects of the ACP and requirements of CAP 725 are presented. PLAS Deployment IoM/Antrim: ACP Benefits Report, referenced as 4162/RPT/70 A17033, (hereafter Benefits Report, presents detailed information of the benefits and dis-benefits declared as result of the ACP. L4162: PLAS Summary of Benefits Analysis for the IoM/Antrim Deployment, referenced as 4162/RPT/71 A17038, (hereafter Benefits Summary, presents summary information of the benefits and dis-benefits declared as result of the ACP. Consultation on revised ATS route structure over the Irish Sea (Isle of Man and Antrim Sectors), Issue 1.1, July 2016. Feedback report for the Consultation on revised ATS route structure over the Irish Sea (Isle of Man and Antrim Sectors of NATS Prestwick Centre), Issue 1, dated 27 th January 2017,(hereafter Feedback report, has also been considered for this environmental assessment. The Feedback report was presented to provide additional information, including information relevant to the environmental assessment, as some airline operators are negatively impacted (regarding fuel consumption and CO 2 emissions) by the proposed ATS structure as it would add track mileage to their routes. These five documents form the basis from which this assessment is made. 2. Guidance to the CAA Status 2.1 Is the proposal consistent with Government policy and/or guidance from Government to the CAA? Yes Guidance issued to the Civil Aviation Authority sets 1 out a framework for the environmental objectives that the CAA must consider when assessing airspace change proposals. In addition to these objectives, there may be other legitimate operational objectives, such as the overriding need to maintain an acceptable level of air safety, the desire for sustainable development or to enhance the overall efficiency of the UK airspace network, which need to be considered alongside these environmental objectives. The Government looks to the CAA to determine the most appropriate balance between these competing characteristics. Flights over National Parks and AONBs are not prohibited by legislation 2 as a general prohibition against over-flights would be impractical. 1 DfT, Guidance to the Civil Aviation Authority on Environmental Objectives Relating to the Exercise of its Air Navigation Functions, January 2014 2 National Parks and Access to the Countryside Act 1949, National Parks (Scotland) Act 2000, and Duties on relevant authorities to have regard to the purposes of National Parks, Areas of Outstanding Natural Beauty (AONBs) and the Norfolk and Suffolk Broads Guidance Note, DEFRA 2005.
Page 3 of 11 Airspace Change Proposal - Environmental Assessment Version: 1.0/ 2016 Government policy focuses on minimising the over-flight of more densely populated areas below 7,000 feet (amsl), but balances this with CO 2 emissions between 4,000 and 7,000 feet (amsl). However, where it is practical to avoid over-flight of National Parks and AONBs below 7,000 feet (amsl), the Guidance asks that the CAA encourages this. 3. Rationale for the Proposed Change Status 3.1 Does the rationale for the ACP include environmental reasons? No As stated by the sponsor, (Page 6, Main document) the systemisation of the IoM/Antrim Sectors is a response to capacity limitations experienced in the sector within the current airspace design (leading to operational delays). In addition, traffic is forecast to increase and, therefore, increasing levels of delays are predicted. The avoidance of delays is the main justification for the changes proposed. The modernisation of the IoM/Antrim sector involves the introduction of RNAV1 and the systemisation involves the introduction of routes mirroring current vectoring practices. In so doing, controller workload will be reduced and, consequently, capacity will be increased. The capacity increase will reduce delays and their cost. The new design means a slight increase in the average track mileage of flight-plannable routes. In particular, Dublin operators on arrival routes are predicted to increase fuel uplifted by 11kg (with 1.7NM median additional track mileage) see Benefits Report. The difference between the current and the proposed flight plannable routes is considered the worst case scenario in terms of fuel dis-benefit, however, as the sponsor states in the Main document (Section 3.7 Environmental Issues) the lengths of tracks flown by aircraft using the proposed route structure are comparable to the lengths of tracks flown by aircraft using the current route structure... doing so in a more systemised way, and the flight plans will be a closer reflection of the actual route of the flight. In addition, the sponsor states, in the consultation to aviation stakeholders (section 6.2) that no impact is expected in terms of fuel consumption or CO 2 emissions due to the similarity of the proposed flight paths with the current vectoring system. 4. Nature of the Proposed Change Status 4.1 Is it clear how the proposed change will operate, and therefore what the likely environmental impacts will be? Yes The sponsor s objective is to modernise and systemise the airspace. The modernisation comes as a result of introducing RNAV1 navigation, replacing the current RNAV5, which will still operate for aircraft without RNAV1 capability. Systemisation is achieved by introducing new flight-plannable routes which mirror the routes used currently for tactical vectoring. By doing so, controller intervention is reduced thus enabling an increase in capacity which in turn will avoid or decrease delays and their subsequent cost. In detail, the sponsor proposes to achieve the objectives of this ACP by: Increasing the number of parallel east-west routes, and northwest-southeast routes. Taking advantage of RNAV1 capabilities the route spacing can be optimised (reduced separation distance required) allowing enhanced systemisation and a more efficient use of airspace
Page 4 of 11 Airspace Change Proposal - Environmental Assessment Version: 1.0/ 2016 In the IoM sector, the introduction of four parallel RNAV1 routes over the Irish Sea between Wallasey and Dublin (east-west), two in each direction, and separated by tactical vectoring area used for both directions. Also the introduction of five RNAV1 routes in the northwestsoutheast direction, mirroring current vectoring practices. The sponsor is clear in that tactical vectoring will still continue to be used by controllers, but they predict the avoidance of delays up until 2022 with the new design (Table 1, Feedback Report). The sponsor states that Systemising the routes would reduce the difference between the flight-planned track and the actual track flown. This has the effect of causing some flight-planned routes to slightly increase or decrease in length to more accurately reflect the likely actual track. The predictability of fuel uplift is improved. It should be noted though that even with improved predictability, aircraft will uplift more fuel if the flight-planned route becomes longer, and vice-versa if the flight-planned route becomes shorter. Dublin aircraft operators would be the worst affected as they need an extra 11kg of fuel uplift per arrival flight at Dublin. Some departure routes from Dublin benefit from a shorter track length, offsetting partially the arrivals extra consumption. However, the sponsor argues that although there is a slight fuel dis-benefit for some operators, the reduced complexity of the airspace will translate into a reduction of delays which in turn brings operational reliability and avoidance of cost of delays. (Note that the impact of or the reasonableness of the claim about delay reduction is not covered by this report.) The prediction of a median of 11kg fuel uplift increase per flight refers to the difference between the flight-plannable routes of the new design versus the current flight-plannable routes, namely it is an enabled increase rather than an actual increase. Current tactical vectoring is not dissimilar to the new proposed routes so this means that the actual fuel consumption difference between the new proposed route and the likely route-vector followed at present is likely to be considerably less than the estimated 11kg per flight. No other environmental impact has been declared. 4.2 Have alternative options been considered, and have the environmental impact of each alternative been assessed? Yes Chapter 6 of the Main document presents analysis of the options considered. The options presented try to address the systemisation and modernisation of the airspace in the IoM/Antrim sectors. A number of alternatives, including do nothing, are presented such as the addition of new COPs (coordination points), closer route spacing, Controlled Airspace (CAS) containment options, airspace reclassification, etc. Some aspects of some rejected alternatives have been progressed but they were all rejected as they would not enable the systemisation of operations in a satisfactory manner. These proposed changes are taking place at an altitude (all above FL75) where there is no direct detriment to non-aviation stakeholders. The only environmental aspect associated with this ACP is the emissions of CO 2 as a result of fuel burn. Fuel dis-benefit has been stated in options presented if relevant (i.e.6.4.2 Main document, page 23).
Page 5 of 11 Airspace Change Proposal - Environmental Assessment Version: 1.0/ 2016 5. Noise Status 5.1 Has the noise impact been adequately assessed? Yes From the Main document, paragraph 5.2 refers to noise analyses (as well as tranquillity, stakeholders on the ground, air quality and biodiversity). The change sponsor argues that all of the proposed changes to flight paths would be above FL75, the majority of which would be above FL170 and over the Irish Sea. There are three instances where the routes cross land, two of which is at FL170 and the third at FL90. Consequently, the sponsor has assessed that there would be no noticeable noise or visual intrusion impact to stakeholders on the ground in these areas, no changes to local air quality, and no direct impact on flora, fauna or biodiversity due to the height of the proposed changes. The CAA accepts this argument. 5.2 Has the noise impact been adequately presented in the consultation and the submitted proposal? Yes As explained in section 5.1, no noise impact assessment was undertaken or consulted on, as the proposed changes would be above FL75, the majority of which would be above FL170 and over the Irish Sea 6. Emissions Status 6.1 Has the impact on CO 2 emissions been adequately assessed? Yes As stated above, the main objective of this ACP is to modernise and to systemise the controlled airspace. Systemisation involves the introduction of new flight-plannable routes which aircraft have previously used for tactical vectoring therefore reducing controller workload. The fuel consumption difference is not significant as a result of this ACP as aircraft will follow a flight-planned route that to a great extent mirrors the vectored route that is currently given by ATC. Nonetheless, there are slight differences in track distance in some routes between the flight-plannable route in the current form and the flight-plannable route proposed in this ACP. In the Main document, section 5.3, the sponsor forecasts an increased fuel uplift of 519 tonnes in 2018 and 633 in 2023 (which would translate into 1,650 and 2,014 tonnes of CO 2 emissions annually respectively if that additional fuel were actually used in order to fly a longer route, Benefits Report, page 22). The Feedback report includes a detailed itemisation of delays, cost of delays, increased fuel burn, cost of extra fuel and overall benefit (Table 1). The economic assessment of delays versus extra fuel and the reduction of complexity of the airspace seem to capitalise the argument for the change, though as noted earlier in this report, the assessment of the reduction in the delays and the sponsor s estimated impacts is not covered in this report. The sponsor states an average increase of fuel uplift of 3 kg fuel per operation. The highest dis-benefit is observed on arrivals to Dublin airport which entails 11 kg extra uplift fuel per operation. All in all, for this ACP, the difference of the flight-plannable routes (current and proposed) translates into an enabled requirement of additional fuel of between 500 and 600 tonnes per year according to the forecast
Page 6 of 11 Airspace Change Proposal - Environmental Assessment Version: 1.0/ 2016 presented in Table 1 of the Feedback report. This theoretical increase in fuel burn due to the increase in flight-plannable mileage can be taken as a worst case impact in terms of CO 2 emissions, as the actual difference in CO 2 emissions is likely to be much less, primarily due to the additional fuel burned as a result of the increase in weight from carrying a small addition of uplifted fuel. 6.2 Has the impact on CO 2 emissions impact been adequately presented in the consultation and the submitted proposal? The impacts on fuel burn and CO 2 emissions were consulted on with aviation stakeholders (there was no consultation with non-aviation stakeholders). The impact on CO 2 emissions has been adequately addressed and presented in the Benefits report. Table 2 and Table 3 of the Benefits report present the necessary information (delays routes, number of movements per route, median track distance change, median fuel burn, annual fuel burn and annual CO 2 emissions change) for 2018 (the year of implementation) and 2023 (implementation year + 5 years). Also, Table 1 of the Feedback report presents a summary of the impacts, including increased fuel burn. The tables presented in the Benefits report address the differences between the current and proposed flight plannable routes, which can be considered the worst case scenario. In the consultation to aviation stakeholders they also state that the proposed routes mirror current vectoring paths, subsequently, noticeable increases of fuel consumption (or CO 2 emissions) are not expected (section 6.2 of consultation document). Yes Item 51 of the list of environmental requirements, page 35 Main document, the requirement specifies that sponsors should estimate the total annual fuel burn for the current situation and the situation following the airspace change Sponsors should produce estimates for each airspace option considered. The sponsor noted Not applicable in that section. Despite the inconsistency in this declaration, the CAA is satisfied with the information supplied by the sponsor in relation to fuel burn and CO 2 emissions. Item 53 of the list of environmental requirements, page 35 Main document, the requirement specifies that where the need to provide additional airspace capacity, reduce delays or mitigate other environmental impact results in an increase in the total annual fuel burn/ mass of carbon dioxide in metric tonnes between the current situation and the situation following the airspace change, Sponsors should provide justification. The sponsor noted Not applicable. The CAA takes the justification of this ACP, modernisation and systemisation, as justification for the increase in fuel burn. The CAA also understands that the fuel burn difference presented is a theoretical one as aircraft are flying at present a set of tracks that are closer in design to the proposed ACP than to the current design. 7. Local Air Quality Status 7.1 Has the impact on Local Air Quality been adequately assessed? Yes The sponsor concluded that the proposed changes would have no impact on Local Air Quality, as the proposed changes would be above FL75, the majority of which would be above FL170 and over the Irish Sea and therefore no detailed assessment was undertaken. The CAA
Page 7 of 11 Airspace Change Proposal - Environmental Assessment Version: 1.0/ 2016 accepts this argument. 7.2 Has the impact on Local Air Quality been adequately presented in the consultation and the submitted proposal? Yes No Local Air Quality assessment was undertaken or consulted on. This is reasonable, as the proposed changes would be above FL75, the majority of which would be above FL170 and over the Irish Sea and thus have no effect on Local Air Quality. 8. Tranquillity Status 8.1 Has the impact on tranquillity been adequately considered? Yes The sponsor concluded that there would be no impact on tranquillity as the proposed changes would be above FL75, the majority of which would be above FL170 and over the Irish Sea. The CAA accepts this argument. 8.2 Has the impact on tranquillity been adequately presented in the consultation and the submitted proposal? Yes No tranquillity assessment was undertaken or consulted on. This is reasonable, as the proposed changes would be above FL75, the majority of which would be above FL170 and over the Irish Sea and thus have no effect on tranquillity. 9. Visual Intrusion Status 9.1 Has the impact of visual intrusion been adequately considered? Yes The sponsor concluded that there would be no impact on visual intrusion as the proposed changes would be above FL75, the majority of which would be above FL170 and over the Irish Sea. The CAA accepts this argument. 9.2 Has the impact of visual intrusion been adequately presented in the consultation and the submitted proposal? Yes No visual intrusion assessment was undertaken or consulted on. This is reasonable, as the proposed changes would be above FL75, the majority of which would be above FL170 and over the Irish Sea and thus have no effect on tranquillity. 10. Biodiversity Status 10.1 Has the impact upon biodiversity been adequately considered? Yes
Page 8 of 11 Airspace Change Proposal - Environmental Assessment Version: 1.0/ 2016 The sponsor concluded that there would be no impact on biodiversity as the proposed changes would be above FL75, the majority of which would be above FL170 and over the Irish Sea. The CAA accepts this argument. 10.2 Has the impact upon biodiversity been adequately presented in the consultation and the submitted proposal? Yes No biodiversity assessment was undertaken or consulted on. This is reasonable, as the proposed changes would be above FL75, the majority of which would be above FL170 and over the Irish Sea and thus have no effect on tranquillity. 11. Continuous Descent Approaches Status 11.1 Has the implementation of, or greater use of, CDAs been considered? Yes The Sponsor states that the incorporation of CDA profiles is not applicable to this proposal (since CDAs normally take place below FL70) and that The changes will not affect the ability of IFR traffic to perform CDAs & LPLD. The CAA accepts this argument. 12. Impacts Upon National Parks and/or AONBs Status 12.1 Does the proposed change have an impact upon any National Parks or Areas of Outstanding Natural Beauty (AONBs)? The sponsor states in section 5.2 of Main document that there would be no noticeable noise or visual intrusion impact to stakeholders on the ground in these areas, no changes to local air quality, and no direct impact on flora, fauna or biodiversity due to the height of the proposed changes. The CAA is satisfied with the sponsor s conclusion. No 13. Traffic Forecasts Status 13.1 Have traffic forecasts been provided, are they reasonable, and have these been used to reflect the future impact of the proposal? Section 3.5 presents the traffic forecast used in the calculations. In 2018 the traffic forecast is that of 2016 +4.8% and in 2023 (implementation + 5 years) is that of 2016 +17.1%. Growth of traffic is not the justification behind this ACP, i.e. the proposal is not being made with the purpose that it will increase traffic over and above the growth that is expected to occur regardless. Yes 14. Consultation Status
Page 9 of 11 Airspace Change Proposal - Environmental Assessment Version: 1.0/ 2016 14.1 If undertaken, has evidence of non-aviation stakeholder consultation been provided? N/A Aviation stakeholders were consulted but consultation with non-aviation stakeholders was not undertaken as local air quality, noise and other deleterious effects of aviation activity were considered not significant (see section 5.2. of the Main document). The changes in this proposal take place typically above FL170, the minimum is FL90 (approx. 9000ft). The CAA agrees with the sponsor s assessment that at that altitude, ground stakeholders would not be negatively affected by the changes proposed. 14.2 Has account been taken of the results of the environmental factors raised by consultees or has evidence been provided to indicate why this has not been possible? No consultation was undertaken. N/A 15. Compliance with CAP 725 Status 15.1 Have all environmental assessment requirements specified in CAP 725 been met, where applicable? Yes The sponsor claims that no changes at or below 7000 ft will take place. Local air quality, noise, AONBs, National Parks, biodiversity, tranquillity and visual intrusion are typically affected by lower flying aircraft. Therefore, the sponsor has not undertaken a specific environmental analysis with regards to those impacts (Chapter 11, Environmental requirements, items 3 and 4). However, all environmental aspects raised in CAP725 have been adequately addressed in the proposal, and most specifically CO 2 emissions have been analysed and estimated. 16. Other Aspects Status 16.1 Are there any other aspects of the ACP, that have not already been addressed in this report, that may have a bearing on the environmental impact? No No 17. Recommendations Status 17.1 Are there any recommendations for the Post-Implementation Review? Yes
Page 10 of 11 Airspace Change Proposal - Environmental Assessment Version: 1.0/ 2016 The sponsor has made a number of assumptions in modelling and analysing the environmental impact of this ACP, principally the effect on fuel burn and CO 2 emissions. They include assumptions on traffic forecast, fleet mix and the representativity of the sample days among others. The sponsor, as part of the Post-Implementation Review, should re-examine the accuracy of the assumptions with actual data at the end of the first year of implementation, aimed at confirming the extent of the environmental impact declared in the documentation of this ACP, or updating it. 18. Government Approval Status 18.1 Is the approval of the Secretary of State for Transport required in respect of the environmental impact of the airspace change proposal? The environmental impact of this proposal is negative but not significant, and therefore it is reasonable to conclude that approval from the Secretary of State is not required. No 19. Conclusions 19.1 Can an overall environmental benefit be demonstrated (or justified/supported)? No The sponsor s main reason for this change is to modernise and systemise the airspace infrastructure in a way that offers less interventions from ATC. There is a small fuel dis-benefit between the current flight-plannable route and the flight-plannable route following this ACP which can be viewed as a worst case increase in CO 2 emissions. There is an even smaller fuel dis-benefit between the actual flight path flown at present and the proposed route design. Outstanding Issues Serial Issue Action Required 1 2
Page 11 of 11 Airspace Change Proposal - Environmental Assessment Version: 1.0/ 2016 Additional Compliance Requirements (to be satisfied by Change Sponsor) Serial Requirement 1 2 Environmental Assessment Sign-off/Approval Name Signature Date Environmental Assessment completed by: Environmental Assessment approved by: Associate Noise Analysis Head Noise Analysis 15/06/2017 30/06/2017 Programme Head - Environment Comments: