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Burbo Bank Extension Offshore Wind Farm TMZ – Final Report on the Stakeholder Consultation

Date: 16 July 2014 Author: Revision: Issue 3 Osprey Ref: 7750 024 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 01420 520200 / [email protected] Registered in England and Wales under No: 6034579

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Document Details

Reference Description

Document Title Burbo Bank – Final Report on the Stakeholder Consultation

Document Ref 7750 024

Issue Issue 3

Date 16 July 2014

Client Name DONG Energy

Classification Nil

Approval Level Authority Name

Author Osprey CSL

Internal Approval Osprey CSL

Burbo Bank – Final Report on the Stakeholder Consultation | 7750 024 | Issue 3

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Executive Summary DONG Energy (DONG) is the Sponsor for a proposed airspace change over the operational Burbo Bank Offshore Wind Farm and its extension (Burbo Bank Extension Wind Farm) at Liverpool Bay. As part of the Civil Aviation Authority’s (CAA) Airspace Change Process (ACP)(CAP 725) [Ref 1], DONG is required to submit a case to the CAA to justify the establishment of a Transponder Mandatory Zone (TMZ) over the Burbo Bank operational and extension Wind Farms, and to undertake a consultation exercise with all relevant stakeholders. This ensures that all stakeholders who may be directly or indirectly affected by the proposed change are consulted, as well as highlighting any environmental impacts that the proposed airspace change may have. DONG has engaged Osprey Consulting Services Ltd (Osprey) to project manage the ACP on their behalf. This document is the Final Report on the consultation carried out by DONG between 31st March 2014 and 4th July 2014 in accordance with the requirements of CAA CAP 725 [Ref 1]. It includes an analysis of all submissions received throughout the consultation and identifies the main issues raised by consultees. It also provides DONG’s views in relation to the issues raised and outlines post-consultation action taken, or planned to be undertaken by DONG. This document will form part of the Airspace Change Proposal submission to the CAA that will detail the case for the proposed TMZ.

Subject of the Consultation The purpose of this consultation was to gather and analyse the views of the various stakeholders concerning a proposal to establish a TMZ over the operational Burbo Bank Offshore Wind Farm and its Extension in the Liverpool Bay. Fundamentally, the aim of the consultation was to enable DONG to obtain or confirm views and opinions about the impact of the proposed airspace change.

Consultees The Consultation Document was circulated to a total of 105 consultee organisations or individuals. The aviation consultees included aviation parties such as the Ministry of Defence (MoD), airlines, aircraft operators, adjacent aerodromes, all local airspace users and the national bodies representing all UK aviation interests who may be affected by the regulatory requirements within the TMZ. National bodies such as LAA, BALPA, AOA etc. are represented through the auspices of the National Air Traffic Management Advisory Committee (NATMAC), sponsored by the CAA. A number of military organisations are also members of the NATMAC. Non-aviation stakeholders for consultation included environmental and heritage organisations, local planning authorities and the general public. Although the proposed change to the airspace lies offshore, and there are no changes to the way aircraft operate over land, the neighbouring coastal districts and parish councils were also consulted. In addition, the views of individual members of the public were welcomed.

Consultation Statistics A total of 25 responses (approximately 24 % of consultees) were received from a total of 105 consultees. Of the 25 responses received from the consultee organisations; seven consultees supported the proposal to establish a TMZ over the Burbo Bank Offshore Wind Farms, 14 provided a neutral response and three objected to the proposal.


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One individual objected to the extension of the operational Burbo Bank Offshore Wind Farm itself and not to the development of the Burbo Bank TMZ. Such comments have therefore not been included in the analysis.

Next Stages The consultation process constitutes the third stage of the CAA’s overall process laid down in CAP 725 [Ref 1] leading to an Airspace Change Proposal. DONG will submit a formal Airspace Change Proposal to the Airspace Regulation (AR) of the CAA detailing the case for the proposed TMZ. Following receipt of the formal Airspace Change Proposal, the CAA then requires a 16-week period to conduct its own internal analysis of the final proposal and consultation results, before arriving at a Regulatory Decision. DONG extend their thanks to all consultees and other individuals who took the time to participate in this consultation and for their very useful feedback.


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Contents 1 Glossary …………………………………………………………………………………………………………………………7

2 Introduction ...................................................................................................................................................................... 10

2.1 General 10 2.2 Subject of the Consultation .............................................................................................................................................................. 10 2.3 Development of the Consultee List ............................................................................................................................................... 11 2.4 Confidentiality ....................................................................................................................................................................................... 11 2.5 Document structure ............................................................................................................................................................................ 11

3 Consultation Statistics ................................................................................................................................................... 12

3.1 Overview 12 3.2 Consultee Organisations ................................................................................................................................................................... 12 3.3 Responses 13 3.4 Meetings with Major Stakeholders ............................................................................................................................................... 14

4 Analysis of Responses .................................................................................................................................................... 15

4.1 Introduction ............................................................................................................................................................................................ 15 4.2 Response support ratio ..................................................................................................................................................................... 15 4.3 Key issues arising from consultee responses .......................................................................................................................... 16 4.4 Objection(s) ............................................................................................................................................................................................ 16 4.5 Irish Sea Concerns................................................................................................................................................................................ 16 4.6 Submissions from other parties .................................................................................................................................................... 17

5 Post-Consultation Actions ............................................................................................................................................ 18

5.1 Post-consultation Review ................................................................................................................................................................. 18 5.2 DONG Conclusions ............................................................................................................................................................................... 18 5.3 Next Stages of the ACP ....................................................................................................................................................................... 18

6 References19

A1 Consultation Background and Methodology .................................................................................. 20

A1.1 Background to the Consultation ............................................................................................................................ 20 A1.2 Method of Consultation ............................................................................................................................................. 20

A2 Stakeholder / Consultee List ................................................................................................................. 22

A2.1 Aviation Consultees .................................................................................................................................................... 22 A2.2 Aerodromes / Local Aviation Consultees .......................................................................................................... 24 A2.3 Non-Aviation Consultees: National Bodies ....................................................................................................... 24 A2.4 Non-Aviation Consultees: Regional Council Authorities ............................................................................ 24 A2.5 Non-Aviation Consultees: Council Wards / Local Authorities ................................................................. 25 A2.6 Non-Aviation Consultees: Town / Parish Councils ....................................................................................... 26 A2.7 Information Organisations: Members of Parliament ................................................................................... 26


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A2.8 Information Organisations: Civil Aviation Authority ................................................................................... 27

A3 Key Issues arising from the Consultation ........................................................................................ 28

Table of Figures Figure 1 Distribution of Consultees ............................................................................................................................................. 13 Figure 2 Responses from Listed Consultees............................................................................................................................. 14 Figure 3 Support Ratio from Listed Consultees ...................................................................................................................... 15

Table of Tables Table 1 Responses from Consultees ............................................................................................................................................ 13


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1 Glossary

Acronym Meaning

ACC Airport Consultative Committee

ACP Airspace Change Process

ACAS Airborne Collision Avoidance System

AEF Air Experience Flight

agl Above ground level

AIP Aeronautical Information Publication

AOA Airport Operators Association

AOPA Aircraft Owners and Pilots Association

AR Airspace Regulation

ARA Advisory Radio Area

ASL Above Sea Level

ATC Air Traffic Control

ATM Air Traffic Management

ATSOCAS Air Traffic Service Outside Controlled Airspace

ATS Air Traffic Service

ATSU Air Traffic Service Unit

BAA British Airports Association

BABO British Association of Balloon Operators

BALPA British Airline Pilots’ Association

BATA British Air Transport Association

BB Burbo Bank

BBAC British Balloon and Airship Club

BBE Burbo Bank Extension

BBGA British Business and General Aviation Association

BBOW Burbo Bank Offshore Wind Farms


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BBW01 Burbo Bank Offshore Wind Farm

BGA British Gliding Association

BHA British Helicopter Association

BHPA British Hand Gliding and Paragliding Association

BMAA British Microlight Aircraft Association

BMFA British Model Flying Association

BPA British Parachute Association

CAA Civil Aviation Authority

CAP Civil Aviation Authority Aeronautical Publication

CAS Controlled Airspace

CAT Commercial Air Transport

CTA Control Area (Class D UK Airspace)

DAATM Defence Airspace and Air Traffic Management

DAP Directorate of Airspace Policy (part of the CAA – now SARG)

DfT Department for Transport

DS Deconfliction Service

ELFAA European Low Fares Airline Association

GA General Aviation

GASCo General Aviation Safety Council

GAT General Air Traffic

GAPAN Guild of Air Pilots and Air Navigators

GATCO Guild of Air Traffic Control Officers

HCGB Helicopter Club of Great Britain

HQ DAAvn Headquarters Director Army Aviation

HTZ Helicopter Traffic Zone

IAIP Integrated Aeronautical Information Package

IFP Instrument Flight Procedure

IoMA Isle of Man Airport

LAA Light Aircraft Association


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LARS Lower Airspace Radar Service

LJLA Liverpool John Lennon Airport

LoA Letter of Agreement

MAA Military Aviation Authority

MoD Ministry of Defence

NATMAC National Air Traffic Management Advisory Committee

NATS The National Air Traffic Service Provider

NERL NATS En-Route Ltd

NCHQ Navy Command Head Quarters

NM Nautical Miles

OS Ordnance Survey

PSR Primary Surveillance Radar

RAF Royal Air Force

SARG CAA Safety and Airspace Regulation Group

SRG Safety Regulation Group (part of the CAA)

SSR Secondary Surveillance Radar

TMZ Transponder (SSR) Mandatory Zone

UAS University Air Squadron

UAV Unmanned Air Vehicles

UKAB UK Airprox Board

UKFSC UK Flight Safety Committee

VGS Volunteer Gliding Squadron

VOR VHF Omni Directional Radio Range; a type of short-range radio navigation system for aircraft

WAL Wallasey VOR


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2 Introduction

This document is the final report of the consultation, carried out between 31st March 2014 and 4th July 2014, on the establishment of a Transponder Mandatory Zone (TMZ) over the operational Burbo Bank Offshore Wind Farm and the Burbo Bank Extension Offshore Wind Farm. The aim of this report is to present details on the statistical data arising from the responses to the consultation, together with an analysis of the feedback received.

2.1 General DONG Energy (DONG) is the Sponsor for a proposed airspace change over the Burbo Bank Offshore Wind Farm and its Extension (Burbo Bank Extension Offshore Wind Farm) in Liverpool Bay. As part of the Civil Aviation Authority’s (CAA) Airspace Change Process (ACP)(CAP 725) [Ref 1], DONG is required to submit a case to the CAA to justify the establishment of a Transponder Mandatory Zone (TMZ) over the Burbo Bank Offshore Wind Farms, and to undertake a consultation exercise with all relevant stakeholders. This ensures that all stakeholders who may be directly or indirectly affected by the proposed change are consulted, as well as highlighting any environmental impacts that the proposed airspace change may have. DONG has engaged Osprey Consulting Services Ltd (Osprey) to project manage the ACP on their behalf. The Burbo Bank TMZ airspace change is hereafter referred to as ‘the proposal’. This document is the final report on the aforementioned consultation. The background to this consultation and the methodology used are detailed in Annex A1 to this document. The aim of this report is to present details on the statistical data arising from the responses to the consultation, together with an analysis of the feedback received. DONG would like to thank all consultees and other individuals who took the time to participate in this consultation and for their very useful feedback.

2.2 Subject of the Consultation The purpose of this consultation was to gather and analyse the views of the various stakeholders concerning a proposal to establish a TMZ over the operational Burbo Bank Offshore Wind Farm and its Extension in the Liverpool Bay. Fundamentally, the consultation will enable DONG to obtain or confirm views and opinions about the impact of the proposed airspace change. The proposed establishment of the TMZ is one element of a three-part Mitigation Package aimed at negating the impact of the clutter from the Burbo Bank Extension Wind Farm WTGs upon the Warton Primary Surveillance Radar (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. Such an airspace change is necessary in order to mitigate the effects of the Wind Turbine Generators (WTGs) on the Warton PSR. This will ensure that a full suite of Air Traffic Service Outside Controlled Airspace (ATSOCAS) can continue to be provided, whilst maintaining the current levels of airspace effectiveness and efficiency in this area. This consultation is not about facilitating change of routine air traffic procedures at local aerodromes.


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2.3 Development of the Consultee List A full list of consultees was developed with the advice of the CAA and is given at Annex A2. At the start of the consultation, DONG sent out a notification to 105 consultees, comprising:

• 38 Aviation “National Organisations” (CAA NATMAC list); • 1 Aviation Association • 10 Local Aerodromes/Aviation Consultees; • 9 Members of Parliament; • 31 Council Wards and Local Authorities; • 10 Town/Parish Councils; and • 6 Local/National Environmental Organisations.

Further detail on the categories of consultee organisations is provided in Section 3.2 of this report.

2.4 Confidentiality All the feedback from the consultation has been made available to the CAA as part of the Airspace Change Proposal. This will allow the CAA to assess independently whether the appropriate conclusions have been drawn in the development of the proposed design. Responses will be treated with due care and sensitivity by us and by the CAA.

2.5 Document structure This document contains six main sections and three Annexes, outlined below for convenience:

• Section 1 provides a glossary; • Section 2, this section, introduces the document; • Section 3 details the consultation statistics; • Section 4 provides an overview of the responses and support ratio; • Section 5 highlights the post-consultation actions; and • Section 6 provides a list of references.

There are three Annexes:

• Annex A1 details the background to this consultation and the consultation methodology;

• Annex A2 lists the consultees; and • Annex A3 details the key issues arising from this consultation.


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3 Consultation Statistics

The Burbo Bank TMZ consultation invitations were circulated to a total of 105 stakeholder consultee organisations or individuals. A total of 25 responses to this consultation were received.

3.1 Overview This section describes the categories of consultee organisations and individuals that were consulted and gives a breakdown of the responses received.

3.2 Consultee Organisations The Burbo Bank TMZ consultation invitations were circulated to a total of 1051 stakeholder consultee organisations or individuals detailed in Annex A2. During the consultation process, the DONG website link was visited more than 500 times. Consultees broadly fall into two categories:

• Aviation consultees; and • Non-aviation consultees.

Aviation consultees included aviation parties such as the MoD, airlines, aircraft operators, adjacent aerodromes, all local airspace users and the national bodies representing all UK aviation interests who may be affected by the regulatory requirements within the TMZ. National bodies such as LAA, BALPA, AOA etc. are represented through the auspices of the National Air Traffic Management Advisory Committee (NATMAC), sponsored by the CAA. A number of military organisations are also members of the NATMAC. Non-aviation stakeholders for consultation included environmental and heritage organisations, local planning authorities and the public. Although the proposed change to the airspace lies offshore, and there are no changes to the way aircraft operate over land, the neighbouring coastal districts and parish councils were also consulted. The consultee groups are detailed in Figure 1 below.

1 It should be noted that NATMAC comprises a total of 38 organisations, represented by 48 individuals. The consultation document was circulated to each individual. However, this analysis reflects the views of the organisations as a whole and not of the individuals representing them. In some cases it was found that representation had changed from the list provided by the CAA.


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Figure 1 Distribution of Consultees

3.3 Responses A total of 24 responses (approximately 23 % of consultees) to this consultation were received. A breakdown of these is provided in Table 1 and Figure 2 below.

Consultee Groups Number Consulted Responses %

1 NATMAC (Civil) 33 9 27.27

2 NATMAC (Military) 5 2 40.00

3 Aviation Associations 1 0 0

4 Local Aerodromes/Aviation Consultees 10 9 90.00

5 MPs 9 0 0

6 Council Wards & Local Authorities 31 3 9.68

7 Parish Councils 10 0 0

8 Environmental Organisations 6 1 16.7

9 Individual N/A 1 N/A

Totals 105 25 23.8 %

Table 1 Responses from Consultees


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Figure 2 Responses from Listed Consultees

It should be noted that “NATMAC (Civil)” and “NATMAC (Military)” comprise those organisations who are members of the CAA’s National Air Traffic Management Advisory Committee (NATMAC). The NATMAC consultee list includes some CAA Departments who, for reasons of CAA impartiality, do not respond to consultations.

3.4 Meetings with Major Stakeholders Prior to the commencement of the consultation period, a number of meetings were held with some of the major stakeholders. Although most of these organisations had been contacted during the initial requirements capture phase, the purpose of these meetings was to present the detail that would be incorporated into the Consultation Document to ensure there were no surprises for stakeholders when it came to formal comment. Consultation meetings were organised with the following stakeholders:

• LJLA; • Bond Offshore Helicopters (Blackpool Airport); and • Caernarfon Aerodrome.


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4 Analysis of Responses

Twenty-five responses were received; seven supported the proposal, 14 provided a neutral response and three objected to the proposal.

4.1 Introduction This section provides details on the number of responses received from the various organisations and individuals that were consulted. It also explores the support ratio of consultee responses received to give a general indication on the stakeholder acceptance of this proposal.

4.2 Response support ratio Of the 25 responses received from the consultee organisations:

• 7 consultees (28 %) supported the proposal to establish a TMZ over the Burbo Bank Offshore Wind Farms;

• 3 consultees (12 %) objected to the proposal; and • 14 consultees (56 %) provided a neutral response, whereby the

consultee did not object or provided no comments on the proposal.

Figure 3 Support Ratio from Listed Consultees

An objection was raised but did not relate to the development of a Burbo Bank TMZ but to the extension of the operational Burbo Bank Offshore Wind Farm itself. This comment has therefore not been included in the analysis. The key issues emanating from the responses received are presented in Annex A3 of this report.


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4.3 Key issues arising from consultee responses The consultation process constitutes the fourth stage of the CAA’s seven-stage ACP (as defined in CAP 725) [Ref 1]. During Stage 1, a requirements capture workshop was organised, at BAE Systems Warton (including representation from LJLA), with the purpose of undertaking a detailed analysis of current operations in the area of the Burbo Bank and the challenges those operations face. The workshop further identified current issues and discussed potential airspace constructs that would meet those challenges. This workshop was followed by a Framework Briefing with the CAA (Stage 3 of the ACP) to outline the proposed airspace change. Also, as stated in Section 3.4 of this document, prior to the commencement of the consultation period, a number of meetings were held with some of the major stakeholders. The purpose of these meetings was to present the detail that would be incorporated into the Consultation Document to ensure there were no surprises for stakeholders when it came to formal comment. Consequently, by the time the consultation stage is reached there should have been few areas of contention, highlighted by the major stakeholders that had not previously been raised and addressed. The Consultation Document itself incorporated all the preliminary feedback received from the major aviation stakeholders. The response analysis process identified a number of key themes in those responses that objected to the proposal. The principle issues and areas of concern, together with DONG and Warton’s consideration of them are detailed at Annex A3 to this report.

4.4 Objection(s) 4.4.1 Light Aircraft Association The Light Aircraft Association (LAA) rejects the arguments and opposes the proposal to establish a substantial TMZ in association with the Burbo Bank Development. This objection is on the basis that the chosen solution would disbenefit General Aviation (GA) operations, but have minimum cost to DONG. The LAA reflects the views of some 8000 members who own and operate some 4000 aircraft which the association oversees on behalf of the UK CAA. The LAA acknowledges that there is no great volume of non-transponder traffic through the area. However, they state that the TMZ will lie on a route that is important because the Liverpool/Manchester area is difficult to cross VFR and they expect that to become more difficult as the TC North Project develops in the next few years. 4.4.2 British Handgliding and Paragliding Association The British Handgliding and Paragliding Association (BHPA) also rejected the proposal. BHPA also concurred with LAA’s views on the proposed TMZ. BHPA stated that whilst the free flight elements of the BHPA members are not interested in the airspace within the proposed TMZ, the powered elements will be affected by the creation of the choke point between the TMZ and the Manchester/Liverpool CAS. BHPA further object to the establishment of a permanent TMZ and believe that not all radar mitigation possibilities have been fully investigated with a number being dismissed for undefined cost and time reasons. BHPA also refer to the Clyde TMZ rejection, stressing that there exist viable alternatives to a TMZ.

4.5 Irish Sea Concerns The Isle of Man Airport (IoMA) accepted that the proposed Burbo Bank TMZ is on the limits of both surveillance cover and IoMA service provision. However, IoMA has concerns over the cumulative effect of wind farm development in the Irish Sea and the use of TMZs as mitigation. IoMA also has concerns in general with the concept of declaring a TMZ active only during the notified hours of a particular Air Traffic Service Unit (ATSU). The IoMA states that’s its response to this consultation is to highlight the cumulative effect of wind farm development in the Irish Sea and raise the issue of the possibility of multiple TMZs within the Irish Sea.


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4.6 Submissions from other parties Only one response was received from an individual who was not included in the formal consultee list detailed in Annex A2. This individual objected in principle to wind energy and the construction of the Burbo Bank Extension Wind Farm. However, as stated earlier, this does not relate to the subject of the consultation and has therefore not been included in the analysis.


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5 Post-Consultation Actions

No new or unexpected issues have arisen which would affect DONG’s proposal to introduce a TMZ over the Burbo Bank Offshore Wind Farms. DONG will submit a formal Airspace Change Proposal to the Airspace Regulation (AR) of the CAA detailing the case for the proposed TMZ

5.1 Post-consultation Review All responses received throughout the consultation period have been subjected to a detailed review and analysis by DONG, in order to identify emerging issues of concern.

5.2 DONG Conclusions Based on the comments received, DONG has concluded that no new or unexpected issues have arisen which would affect DONG’s proposal to introduce a TMZ over the Burbo Bank Offshore Wind Farms.

5.3 Next Stages of the ACP The consultation process constitutes the third stage of the CAA’s overall process laid down in CAP 725 [Ref 1] leading to an Airspace Change Proposal. DONG will submit a formal Airspace Change Proposal to the Airspace Regulation (AR) of the CAA detailing the case for the proposed TMZ. It is a requirement of the consultation process that DONG will provide the CAA with full details of the consultation (including copies of responses and correspondence) together with all documentation necessary for the promulgation of the proposed TMZ. Following receipt of the formal Airspace Change Proposal, the CAA then requires a 16-week period to conduct its own internal analysis of the final proposal and consultation results, before arriving at a Regulatory Decision. Should the CAA, without the need for further design optimisation or analysis, accept the Airspace Change Proposal, DONG suggest that the implementation of the TMZ would take place on a single date to coincide with the full operational date of the Burbo Bank Extension Offshore Wind Farm, expected to be in late 2015.


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6 References

Reference Name Origin

1 CAP 725 CAA Guidance on the Application of the Airspace Change Process

Third Edition (corrected) April 2007

CAA

ISBN 978 0 11790 739 3

2 Code of Practice on Consultation

July 2008

Cabinet Office

URN 08/1097

Table 1 Table of References


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A1 Consultation Background and Methodology

A1.1 Background to the Consultation DONG wishes to develop an extension to the existing Burbo Bank Offshore Wind Farm, referred to as the Burbo Bank Extension Wind Farm. The presence of the Burbo Bank Extension Offshore Wind Farm WTGs would affect BAE Systems Warton Aerodrome flying and Air Traffic Service (ATS) operations thereby requiring a change to the arrangements and procedures in the immediate airspace surrounding the wind farms. In order to mitigate the effects of the detection of unwanted wind turbine radar returns by the Warton Primary Surveillance Radar (PSR), it is proposed to establish a Transponder Mandatory Zone (TMZ) over the Burbo Bank Offshore Wind Farms. DONG, as the sponsor of the proposed airspace change, is required to submit a case to the Civil Aviation Authority (CAA) to justify the change in airspace over the Burbo Bank Offshore Wind Farms. Also, as part of the CAA’s Airspace Change Process, it is DONG’s responsibility to consult with all relevant stakeholders who may be directly or indirectly affected by the proposal.

A1.2 Method of Consultation The Burbo Bank TMZ consultation was conducted in accordance with the principles set out in the Cabinet Office Code of Practice on Consultation [Ref 2], as required by the CAA. Osprey on behalf of DONG prepared a comprehensive Consultation Document, approved by the CAA Safety and Airspace Regulation Group (SARG). Full details of the proposed change, including rationale, perceived impacts and the mitigation measures undertaken by DONG and Warton, were provided in the Consultation Document. A link to the Consultation Document was made available on the DONG website2. All consultees were notified by email detailing the consultation and how to access the Consultation Document. Local aviation stakeholders were engaged at an early stage during the design process. Prior to the preparation of the Consultation Document, meetings were conducted with the following major stakeholders:

• Liverpool John Lennon Airport (LJLA); • Bond Offshore Helicopters, BIA (helicopter operators to the Liverpool and Morecambe Bay gas

fields and the Search and Rescue helicopter based at Caernarfon Aerodrome); and • Caernarfon Aerodrome (Bangor).

The primary purpose of these meetings was 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. Full consultation commenced with wide circulation of the electronic Consultation Document to all identified stakeholders on 31st March 2014 on completion of the design process and environmental studies. The consultation process was planned to run until 29th June 2014 - a period of 13 weeks. This

2 http://www.burbobankextension.co.uk/en/application-for-consents/consultation-for-transponder-mandatory-zone-(tmz)

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allowed a minimum of twelve weeks required for formal consultation3, recognised the number of Public Holidays during the period and provided scope for any unforeseen delays at the start, or any significant issues that might arise during the process. Due to some technical issues with the DONG consultation website, stakeholders were unable to access the consultation document in late June 2014 for a period of four days. The consultation period was consequently extended to 4th July 2014, lengthening the duration of the consultation to 14 weeks. Consultees were asked to consider the proposal and submit a response to DONG in writing or through a dedicated email address ([email protected]). In order to promote maximum response, two reminder emails were sent to those consultees who had not yet provided a response to date. The first email reminder was sent, on 19th May 2014 (more than one month before the end of the consultation period), to all consultees listed at Annex A2 who had not responded by that date. A second email reminder followed on 17th June 2014 to only the Aviation Stakeholders (NATMAC) who had not responded by that date.

3 The Cabinet Office Code of Practice on Consultation [Ref 2] and the CAA requirements specify a minimum period of 12 weeks for consultation.

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mailto:[email protected]

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A2 Stakeholder / Consultee List

A2.1 Aviation Consultees

National Organisations (NATMAC)

Consultee Also known As

Aircraft Owners and Pilots Association AOPA UK

Airport Operators Association AOA

Aviation Division Navy Command Headquarters NCHQ

Aviation Environment Federation AEF

BAESystems Warton BAES

British Air Transport Association BATA

British Airline Pilots’ Association BALPA

British Airports Association BAA

British Airways BA

British Association of Balloon Operators BABO

British Balloon and Airship Club BBAC

British Business and General Aviation Association BBGA

British Gliding Association BGA

British Hang Gliding and Paragliding Association BHPA

British Helicopter Association BHA

British Microlight Aircraft Association BMAA

British Model Flying Association BMFA

British Parachute Association BPA

Civil Aviation Authority CAA SRG

Defence Airspace and Air Traffic Management (incl. the Military User Advisory Consultative Team) DAATM (MUACT)

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Euro UAV Systems Centre Ltd

European Low Fares Airline Association ELFAA

General Aviation Safety Council GASCo

Guild of Air Pilots and Air Navigators GAPAN

Guild of Air Traffic Control Officers GATCO

Headquarters Director Army Aviation HQ DAAvn

Heavy Airlines

Helicopter Club of Great Britain HCGB

Light Aircraft Association LAA

Light Airlines

Low Fares Airlines

Ministry of Defence MOD

MoD Flight Test Regulator

NATS (NSL) NSL

NATS En-Route Ltd NERL

PPL/IR Europe PPL/IR

The British Business and General Aviation Association BBGA

UK Airprox Board UKAB

UK Flight Safety Committee UKFSC

3 AF-UK/A3

Aviation Associations

Consultee

Association of Manx Pilots


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A2.2 Aerodromes / Local Aviation Consultees


Blackpool International Airport EGNH

Bond Offshore Helicopters

Caernarfon Aerodrome Bangor

Chester Hawarden EGNR

City (Barton) Heliport Manchester

EGCB

Ince West Lancashire Microlight

Isle of Man Airport EGNS

Liverpool John Lennon Airport EGGP

Lleweni Parc Airfield Denbigh Gliding

RAF Woodvale EGOW

A2.3 Non-Aviation Consultees: National Bodies

Consultee

National Trust for England

Cadw, Welsh Government (Environmental Group)

English Natural Heritage

Friends of the Earth

Campaign to Protect Rural England

Natural England

A2.4 Non-Aviation Consultees: Regional Council Authorities

Consultee

Liverpool Council

Sefton Council

Wirral Council


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A2.5 Non-Aviation Consultees: Council Wards / Local Authorities

Metropolitan Borough of Liverpool

Consultee

Fazakerley

Warbeck

County

Kirkdale

Metropolitan Borough of Sefton

Consultee

Ainsdale

Birkdale

Blundellgands

Ford

Harrington

Kew

Linacre

Litherland

Meols

Netherton and Orrell

Ravenmeols

Metropolitan Borough of Wirral

Consultee

Bidston and St James

Claughton

Greasby, Frankby and Irby


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Heswall

Hoylake and Meols

Leasowe and Moreton East

Liscard

Moreton West and Saughall Massie

New Brighton

Pensby and Thingwall

Seacombe

Wallasey

West Kirby and Thurstaston

A2.6 Non-Aviation Consultees: Town / Parish Councils

Metropolitan Borough of Sefton in Merseyside

Consultee Town / Parish

Aintree Village

Formby

Hightown / Little Altcar

Ince Blundell

Lydiate

Maghull

Melling

Sefton

Thornton

A2.7 Information Organisations: Members of Parliament

Consultee Constituency

MP Wirral South


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MP Wallasey

MP Sefton Central Constituency

MP Wirral West

MP Southport

MP Bootle Constituency

Riverside

MP Birkenhead

Walton

A2.8 Information Organisations: Civil Aviation Authority


Safety and Airspace Regulation Group SARG

Safety and Airspace Regulation Group Head of Aerodrome & Air Traffic Standards Division SARG AAA Manager Aerodromes

Safety and Airspace Regulation Group Flight Ops Division SARG Flight Ops Division

Safety and Airspace Regulation Head of Airspace Regulation SARG AAA Manager Airspace Regulation


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A3 Key Issues arising from the Consultation

Issue Specimen Comment DONG/Warton Comment

1 Displaced traffic forced to the northwest of the TMZ

Displaced traffic might be forced to the North West of the TMZ and enter the Southern portion of the Liverpool Bay Gas Field HTZ below 2000 ft (amsl).

This was deemed a minor issue as traffic surveys to date have indicated that all VFR air traffic movements in the Burbo Bank are transponder equipped or tend to move along the coast to the south and east of the area.

2 Assessment of the economic benefit of the project

The assessment of economic benefit (Section 7.6 of the Consultation Document) suggests avoidance of the re-routing of air traffic is an efficiency measure, but the only reason for re-routing would result from the extension of the Burbo Bank site; this efficiency is based on a false premise and should be removed from the proposal.

Economic benefit lies solely in the project because establishing the TMZ can only be done at a cost to industry (staff time, training, documentation, charts etc).

This was deemed a minor issue as DONG are prepared to accept the cost of mitigation for the Warton PSR as part of the Wind Farm Project. There would be no economic loss to airspace users or ANSPs.

3 Mode S exemption for military aircraft

The military has exemptions to the carriage and operation of Mode S for some of its aircraft which it would expect to continue to apply within this TMZ (Mode 3/A and C would be operated by Mode S exempt aircraft).

Subject to the continuance of existing Mode S exemptions for airspace, within this TMZ, that have been agreed with the

Continuance of existing Mode S exemptions for the purposes of access to the TMZ airspace is accepted.

Burbo Bank – Final Report on the Stakeholder Consultation | Key Issues arising from the Consultation 7750 024 | Issue 3

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CAA, the MOD support the proposal.

4 Impact on Light Aircraft operations

Although there is no great volume of non-transponder traffic through the area, it is an important route because the Liverpool/Manchester area is difficult to cross VFR and we expect that to become more difficult as the TC North Project develops in the next few years. So this area is relevant to our operations.

The LAA has accepted the establishment of TMZs in association with the construction of wind turbine projects but our support has been for a temporary arrangement whilst radar mediation programmes are put in place.

We would not expect a simple modification to be possible in a PSR system, it is bound to be complex and involve the expense of development and installation. Your wind turbine array is a substantial and complex project so the mediation needed for the Warton PSR would be in line with that.

Moreover, you have identified that an additional radar would be needed but you say "that would be a lengthy exercise". Your use of these specific words suggesting some unmanageable timescale do you no credit. An additional PSR could certainly be installed and integrated in a useful timescale provided that you fund it properly and this is something you must do.

You reject the additional PSR option "the timescales around definition, selection and implementation of a technical PSR solution do not meet these timescales" and here you refer to the need for you to close the financial arrangements by the end of 2014. We regret that you should have made proper

All mitigation options were considered with BAE Systems (BAES) and the Defence Infrastructure Organisation (DIO), the MoD body responsible for safeguarding the aviation operations at BAES Warton. It was BAES Warton’s preference/proposal made to the developer, DONG, for the TMZ solution/mitigation.

It is not envisaged that the TMZ will be in place for the 25 year lifetime of the Wind Farms, although the proposed TMZ cannot be considered as temporary in the short-term. It is expected that within the Wind Farms’ lifetime, radar technology will advance and systems will be available to mitigate the impact of WTGs on primary surveillance radar thus removing this TMZ type mitigation requirement within the medium-term.

Two traffic surveys of one month’s duration were conducted (in February and June this year). Throughout both survey periods the flow of general aviation (sports & recreation) was along the coastline, not directly crossing the area of the proposed TMZ. Furthermore, all traffic (apart from one isolated event) was transponding and all traffic was in contact with Blackpool, Warton or Liverpool ATCs. Warton maintain that for aircraft without transponders,


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plans in an adequate timescale and your self-imposed deadline, which may be to capture greater subsidies, is a problem for you and not for us. We do not accept that this is a valid deadline nor a valid reason to avoid funding a prompt remediation programme.

Reject your arguments and oppose the proposal on the basis that the solution would disbenefit GA operations but would have minimum cost to DONG.

provided two-way radio contact is maintained, access to the proposed TMZ will very rarely be refused. Any refusal will only occur when a particularly complex trial or evaluation mission is reaching completion within the geographical confines of the proposed TMZ.

5 Multiple TMZs in the Irish Sea

Concerns over the cumulative effect of wind farm development in the Irish Sea and the use of TMZs as a mitigation rather than the developer providing a technical mitigation.

Result in the vast majority of the Irish Sea, including the areas adjacent to airway L10 and IoMA CAS being covered by TMZs.

CAP 764, CAA Policy and Guidelines on Wind Turbines, warns, with respect to TMZs, against the creation of ‘choke points’ in Class G airspace and states that ‘In many instances, the ability to identify non-transponding aircraft (for example, following equipment failure) will be required to maintain safety cases’. This is particularly important for operations close to the boundaries of CAS.

Concerns with the concept of declaring a TMZ active only during the notified hours of watch of a particular ATC agency which, as is the case with Warton ATC, does not routinely operate at weekends or Bank Holidays.

This particular proposed TMZ is on the limits of IoMA surveillance cover. Recent traffic surveys completed at BAES Warton confirm that air traffic in, or close to, the geographical confines of the proposed TMZ are not in contact with IoMA. Two-way radio contact for traffic in this area is with Blackpool, Warton, or Liverpool ATCs. These units will benefit when Warton is open, as the TMZ will preserve efficient use of the adjacent airspace when BAES Warton aircraft are operating in or near the proposed TMZ. There is no requirement for the TMZ when BAES Warton operations are closed. The ATC units closest to, with surveillance cover in, the proposed TMZ are satisfied with this arrangement.

The traffic survey has also demonstrated that it is unlikely that ‘choke points’ will be created near this proposed TMZ as all traffic in the area was transponder equipped (SSR-equipped) or been provided with an Air Traffic Service (ATS).


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Warton maintain that for aircraft without transponders, provided two-way radio contact is maintained, access to the proposed TMZ will very rarely be refused. Any refusal will only occur when a particularly complex trial or evaluation mission is reaching completion within the geographical confines of the proposed TMZ. Safety Casework associated with this proposal has been provided in line with the requirements of CAP725, Airspace Change Process Guidance Document.

6 Impact on handgliders and paragliders

Whilst the free flight elements of the BHPA membership are not interested in the airspace within the proposed TMZ the powered elements will be or will be affected closer in by the creation of the choke point between the TMZ and the Manchester/Liverpool CAS.

The consultation document only says that there may be problems. Unless there are actual problems then there is no need for a permanent TMZ.

It is apparent that not all the radar mitigation possibilities have been fully investigated with a number being dismissed for purely undefined cost and/or for time reasons. If time is a genuine problem then a temporary TMZ could be requested.

As demonstrated by the Clyde TTMZ rejection there can be alternatives to a TMZ that are viable.

A LoS analysis undertaken as part of the planning application for the Burbo Bank Extension Offshore Wind Farm has concluded that it is highly likely that the Warton PSR will detect all WTGs located within the planned extension area.

All mitigation options were considered with BAE Systems (BAES) and the Defence Infrastructure Organisation (DIO), the MoD body responsible for safeguarding the aviation operations at BAES Warton. It was BAES Warton’s preference/proposal made to the developer, DONG, for the TMZ solution/mitigation.

It is not envisaged that the TMZ will be in place for the 25 year lifetime of the Wind Farms, although the proposed TMZ cannot be considered as temporary in the short-term. It is


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expected that within the Wind Farms’ lifetime, radar technology will advance and systems will be available to mitigate the impact of WTGs on primary surveillance radar thus removing this TMZ type mitigation requirement within the medium-term.


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