Response to the Exeter Airport ACP Consultation by the Devon Strut of the Light Aircraft Association.
1. The Devon Strut of the LAA (the Strut) has a membership of over 180 and, as such, is the largest member organisation of general aviation participants in the south west of England. Its members include private pilots, glider pilots, hang glider and paraglider pilots, commercial pilots, ex-military personnel and flight instructors with a wide experience of operating a spectrum of GA and ultralight aircraft from aerodromes and grass airfields in the Exeter and East Devon class G airspace over many years.
2. The Strut acknowledges that:
1)Exeter Airport considers that although current operations are safe, there have been occasions where the prevalence of unknown aircraft operating near Exeter could have potentially led to a degradation of safety margins, such that,
2)Exeter Airport considers that this potential risk justifies the development of controlled airspace in order to provide an enhanced level of ATC efficiency and a “known environment”.
3. The Strut considers that:
3.1 Not all the bodies listed in the Local Airspace User Group have been notified of the ACP. In particular no contact has been made by the Airport with Watchford Farm airfield. No direct approaches were made to the Devon & Somerset Condors hang gliding club nor the Upottery Hang Glider Towing Group, both well-established aviation clubs likely to be significantly affected by the ACP. Hence, the consultation has been incomplete.
3.2 The data on projected Air Transport Movements published to support the need for the proposed design of class D is contentious, misleading and is not supported by data published by IATA and the ONS, which suggest that average annual movements at Exeter have barely maintained the levels recorded in 2005 and that projected demand for commercial passenger flights, post Brexit, will decline by 8-9% rather than increase.
3.3 The published proposals for airspace are excessive, complex and disproportional to the perceived risks requiring IFR CAT protection and deconfliction intervention.
3.4 The proposed plan fails in 3 of the 5 principal objectives for the design of CAS surrounding the airport, namely:
•To make the airspace more efficient for all users;
•Be of the minimum practicable dimensions, commensurate with the regulatory and environmental requirements and the safe and efficient use of airspace;
•Provide for access to the maximum extent practicable by all classes of aircraft.
3.5 The above principles, and Exeter’s quoted desire to minimise the impact to local aviation stakeholders, have not been met in relation to gliding operations from North Hill, hang gliding and paragliding operations from Upottery, and vintage & light aircraft operations from Watchford Farm.
3.6 At Watchford Farm, where the majority of the 2 dozen based vintage aircraft (some non-radio) are owned by Devon Strut members, although the centre of the airfield falls outside the footprint of the proposed class D design, the circuit would be under the north east corner of CTA-4 where the base is 3,000ft, giving headspace of 2,160ft. This would affect activities such a practice force landings and aerobatics.
3.7 The Strut understands that the proposed LoA and glider box concepts described in the ACP to facilitate gliding operations from North Hill have not been agreed and totally fail to demonstrate an understanding by the Airport of local soaring and cross-country gliding activities that have been an essential part of the North Hill gliding history for many years.
4. Airspace Redesign
4.1 The Strut suggests that in order to remove the unjustified impositions on operations at the above locations, the airspace design should be modified to remove all CTA blocks to the north west, north and north east of the proposed Exeter CTR. This would create a one-sided CTA to the south, as used by the London airports and at other locations across Europe. Gatwick has significantly more ATMs than Exeter but operates effectively with CAS which is a fraction of the size proposed by Exeter.
4.2 This one-sided CTA/CTR to the south would require some traffic to & from the north to route using CAS south of the 08/26 centreline, crossing abeam the airport and make descents / climb-outs via the southern sectors of the published plan that could accommodate the desired principles of Continuous Descent Approaches (CDAs) and Continuous Climb Departure (CCD) profiles.
4.3 The base of CTA-1 to the west of Exeter should be raised to 3,000ft ( to match that of the approach stub to the east) and be contiguous with CTA-4 as the suggested base of 2,000ft to the west provides inadequate headspace for transiting traffic over the high ground in that (Haldon) area
4.4 The existing “EX” NDB hold was not designed with CAS in mind and the “EX” hold / approach procedures should be re-designed such that aircraft in the hold are kept out of class G airspace to the north & north west of the “EX”. An RNAV hold would be expected to be part of the new design but if an NDB hold is needed for training or other operational purposes it should be redesigned to fit within the essential CAS or be established outside CAS to the south.
4.5 Line of sight radio exchanges between the Airport and GA traffic transiting the south coast is notoriously difficult at points east of Seaton and the Axminster VRP at altitudes below 2,000ft. In reviewing the location of VRPs, consideration should be given to enhancing the Airport’s radio communications capability.
4.6 The Strut supports the concept of a discrete Listening Squawk for the use of transponder equipped GA traffic transiting the Exeter area.
5.1 The Strut believes the proposed class D airspace design published in the ACP is excessive for the desired objectives of protecting inbound & outbound traffic and providing a known environment.
5.2 Exeter’s proposals would impose significantly on the established operations at local airfields to the north of the Airport.
5.3 An alternative design is suggested that comprises a CTA/CTR combination to the south of Exeter and which would have minimum impact on other GA/gliding activities but provide the necessary protection to Exeter’s inbound & outbound IFR traffic.
Chairman, LAA Devon Strut