Cardiff Airport RNAV Replications:

Consultation Feedback Report

April 2015

Prepared by:

Cardiff Airport Limited in conjunction with NATS

Contents

1. Introduction .................................................................................................................................................... 3

2. Confidentiality ................................................................................................................................................ 4

3. Consultation Engagement ............................................................................................................................... 5

3.1 Introduction ........................................................................................................................................... 5

3.2 National Air Traffic Management Advisory Committee ........................................................................... 5

3.3 Cardiff Airport Consultative Committee ................................................................................................... 5

3.4 Local Authorities ....................................................................................................................................... 5

3.5 Airlines....................................................................................................................................................... 6

3.6 Others ......................................................................................................................................................... 6

4. Statistics ......................................................................................................................................................... 7

5. Consultee Responses ...................................................................................................................................... 9

5.1 Consultee Responses Summary ................................................................................................................. 9

5.2 Issues Arising from Objections ................................................................................................................ 10

5.2.1 Responses to Issues arising from objections ............................................................................................ 10

5.3 Summary of intended Airspace Change Proposal .................................................................................... 11

5.4 Feedback to Consultees ............................................................................................................................ 12

5.5 Post Implementation Review ................................................................................................................... 12

6. Further Correspondence and Feedback ........................................................................................................ 13

7. Consultation Emails & Web Text................................................................................................................. 14

7.1 Email sent to consultees at the start of the consultation ........................................................................... 14

7.2 Cardiff Airport Web Landing Page Text ................................................................................................. 14

Appendices ............................................................................................................................................................ 16

Appendix A – List of consultees ....................................................................................................................... 16

1. Introduction

Between 16th

December and 24th

March, Cardiff International Airport Limited carried out a consultation, seeking

feedback from stakeholders on a proposal to replicate and implement the current conventional approaches, with

more accurately defined routes utilising the capabilities of modern aircraft – namely Area Navigation (RNAV).

The use of RNAV will enhance navigational accuracy and should introduce a number of key benefits. These

include:

- a safer and more efficient Air Traffic Control (ATC) system requiring less controller intervention;

- more efficient operations leading to reduced cost, flying time and emissions;

- the ability to allow more predictable patterns of over flight as well as stabilised arrivals and approaches

which should generate less noise.

By giving pilots a defined flight path from beginning to end they can plan a descent which avoids level

segments, optimises power settings and speed in the descent, configures the aircraft for minimum noise, reduces

fuel burn and keeps the aircraft higher over the ground for longer; such operations are known as Continuous

Descent Operations. The introduction of RNAV replications at Cardiff, to compliment the current conventional

procedures, will enable more effective and reliable use of Continuous Descent Operations.

This report describes the consultation process, and sets out the issues and key themes identified by consultees.

The majority of responses were supportive or raised no objections to the RNAV proposals. Where issues were

raised, Cardiff International Airport Limited have considered these carefully and decided that it would not be

appropriate to make changes to the proposed design of the routes. These issues are set out in this report with

explanations of why the changes suggested have not been carried forward.

Cardiff International Airport Limited is now proceeding to seek the Civil Aviation Authority’s (CAA) approval

to the Airspace Change Proposal (ACP) with a view to implementing the changes in December 2015.

This document should be read in consultation with the Stakeholder Consultation document, available in both

English and Welsh at www.cwlfly.com/rnav consultation document/ All technical terms and acronyms are

explained in full in the consultation document.

2. Confidentiality

The CAA Safety and Airspace Regulation Group (SARG) requires that all consultation material, including

copies of responses from stakeholders, is included in any formal ACP submission to the CAA. Where

specifically requested, details which may identify an individual will be removed before submission.

Cardiff International Airport undertakes not to disclose the personal details or content of responses and

submissions to any third parties, apart from the necessary submission of material to the CAA and essential use

by our consultants for analysis purposes in developing this report and subsequent ACP material.

3. Consultation Engagement

This section details the methods that were used to engage with consultees.

3.1 Introduction

A detailed consultation document was prepared by Cardiff International Airport Limited with the assistance of

NATS Limited. The document explained the RNAV proposals and how it would affect various stakeholders. The

consultation document was posted on the Cardiff Airport website at http://www.cwlfly.com/rnav consultation

document

Formal Consultation began on 15th

December 2014. On the following day (16th

December) an email was sent to

the National Air Traffic Management Advisory Committee (NATMAC – see Appendices) membership outlining

the proposal and how to access the consultation document. Comments were invited by the close of the

consultation on 24th March 2015 (a 14 week duration).

Prior to this, members of the Cardiff Airport consultative committee were provided with an outline of the

proposals made in the consultation document at their meeting on 11th

December 2014. The members of the ACC

voted to support the proposal with the exception of the local council members who abstained from voting until

they had had sufficient time to review the proposals in details.

Complete details of the engagement activities are given below whilst the list of organisations invited to respond

to the consultation and details of other organisations who responded are given in the Appendices.

3.2 National Air Traffic Management Advisory Committee

Consultation invitations were sent out to 25 members of the NATMAC (distribution list held at Appendix A) of

which 3 responded. NATS, Guild of Air Traffic Control Officers (GATCO) and the British Gliding Association

(BGA) - all raised no objection.

3.3 Cardiff Airport Consultative Committee

A presentation of the proposed change was given to members at the committee meeting held on 11th

December

2014. See Appendix B for a list of attendees. Cardiff Airports Head of Airfield Operations and NATS Manager

Operations and Training gave a presentation explaining the proposals to the committee. This was followed by a

question and answers session first from board members and then members of the public.

The consultative committee discussed its response to the proposal where Cardiff Airport Head of Airfield

Operations and NATS Manager Operations and Training responded to comments about concentration of tracks

and funding. The committee resolved to support the proposal and this is recorded in the minutes of the meeting

and by email from the chair of the ACC.

3.4 Local Authorities

Five local authority councils whose areas fall under the flight paths were invited to respond to the consultation

(see Appendix A for a list of council consultees), one of these are also represented on the Airport Consultative

Committee.

A ‘chaser’ email was sent on 5th March 2015 to the councils and responses were received from Vale of

Glamorgan Council and Vale Tourism Association. These two respondents both supported the proposal.

3.5 Airlines

Consultation invitations were sent out to aircraft operators via their NATMAC representatives, with individual

email reminders to 4 airlines and telephone prompts to 3 (a total of 7 individual airline reminders) airlines who

regularly use the airport. Four airlines responded in total, three in support of the proposal whilst one airline

raised no objection.

3.6 Others

A response was received directly from one member of the public, objecting to the proposal. Feedback is

provided in “5.2 Issues Arising from Objections”. A copy of the Consultation feedback document has been sent

directly to the consultee.

4. Statistics

A total of 39 organisations were invited to respond to the consultation; the breakdown of these shown in Figure

1:

Figure 1: Breakdown of 39 unique consultees

The response rate from invitees and other1 organisations is given in Figure 2, with a percentage figure

representing the response rate within each group. 12 responses were received in total.

Figure 2: Response Rate of Consultees

The nature of all of the responses (support, no objection or object) is given in Figure 3 as a percentage of overall

responses received:

1 ‘Other’ represents organisations not explicitly invited to respond but who did respond.

251

5

7

1

NATMAC

ACC

Local Council

Airlines

Military

25.00%

8.33%

16.67%

33.33%

8.33%

8.33%

NATMAC

ACC

Local Council

Airlines

Military

Other (N/A)

Figure 3: Nature of the responses

50.00%

41.67%

8.33%

Support

No Objection

Object

5. Consultee Responses

5.1 Consultee Responses Summary

The consultation covered approaches to both Runways at Cardiff Airport (runway 12 and runway 30). See Figure

4 below.

Figure 4: Approach route labelling from the Consultation Document

The consultation was targeted at Local authorities, the ACC and NATMAC. The consultation document was

made available to wider stakeholders and the general public through a link on the Cardiff Airport website.

The consultation document was drafted using language to make it as accessible as possible to non-aviation

consultees and was also made available in the welsh language. From this, 1 response was received from

organisations or individuals who had not been explicitly invited to respond, resulting in a total of 12 responses.

Of these 12 responses, two came from local authorities, one from the Military and three from the NATMAC List.

Airlines were invited to respond via the NATMAC list and were reminded individually with a total of 4 airlines

responding.

Each response, either group or individual organisation, has been included in the statistical measures. This gives

the following results, as illustrated in Figure 3.

• 6 – Support

• 5 – No Objection

• 1 – Objection

5.2 Issues Arising from Objections

There were three separate issues raised in the objection received to this proposal.

1 – “The report highlights that RNAV is designed to keep aircraft "higher over ground for longer".

However the proposal does not provide the descent heights approaching Runway 12, which may mean

that aircraft are lower and noisier as they pass close to Llanblethian.

New proposals should actually keep aircraft higher for longer during the descent and then descend to

the airport closer to the runway to minimise noise to residents.”

2 – “This CAA and this proposal only considers noise affecting new residents, and makes no

consideration to those residents already affected by noise from aircraft. This should be considered to

improve the impact of the airport on residents.”

3 – “Also the current flight path of aircraft approaching Runway 12 shows aircraft coming from the

north taking a short cut closer to Llanblethian. No change to this is mentioned.”

The respondent also makes a generic statement that

“In summary, the proposal lacks detail in specific areas regarding height of approaches, the affect

on current residents and straying aircraft taking short cuts over residential areas.”

5.2.1 Responses to Issues arising from objections

1 – The consultation document shows current typical aircraft heights in bands for the approaches to

Cardiff Airport for both runways (see consultation document Figures 3 & 5). Taking runway 12 as an

example, the aircraft are anticipated to operate at similar heights as they do today however the

consultation document illustrated the lowest level at which an aircraft operating an RNAV approach

procedure is anticipated to be (see consultation document Figures 10 & 11). The consultation document

indicated that the aircraft will be at 2400ft when joining the RNAV approach at the Initial Approach Fix

and would stay at this height until reaching the Top of Descent point before descending to the threshold.

The IAF and the TOD are clearly marked on the maps in the consultation document and represent a

‘worst case’ scenario.

The text within the document states that aircraft are more likely to maintain the heights which they

operate at today as illustrated in the current typical height bands (Figures 3 & 5). What is not

mentioned or illustrated however, is the case that aircraft today have the option to descend to 1500ft in

the area of the Final Approach Fix if they request to do so. Conversely, aircraft following RNAV

procedures are not expected to do this.

The fact that current height bands and worst case scenario future heights were represented in the

consultation document, gives Cardiff Airport confidence that the objection to the proposal as stated,

does not justify a change to the proposal as presented.

Aircraft aim to descend at a standard rate of 5.2% (3 degrees) as today and this proposal does not look

to alter that.

2 – This proposal is written in the spirit of The Governments overall policy on aviation noise, as

established in the Aviation Policy Framework, which is to limit and where possible reduce, the number

of people in the UK significantly affected by aircraft noise.

Consistent with this policy, the Government believes that in most circumstances, it is desirable to

concentrate aircraft along the fewest possible number of specified routes in the vicinity of airports and

that these routes should avoid densely populated areas as far as possible.

The proposed procedures have been designed to follow those areas where aircraft fly today, and using

the RNAV technology ensure that a high degree of track keeping accuracy is maintained.

3 – This particular ‘short cut’ was not mentioned explicitly in the text of the consultation document.

However, as the number of aircraft utilising RNAV approach procedures increase and follow the

accurate track keeping proposed it is reasonable to expect the number of aircraft flying a ‘short cut’

route in the proximity to Llanblethian to decrease. This change will happen over time as more aircraft

and crew are certified in the use of RNAV approaches.

5.3 Comments arising from no objections

One ‘no-objection response’ was received which contained the following four comments,

1- Thomson Airways pilots will generally prefer to fly an ILS approach, because an RNAV approach is a

non-precision approach. However, an RNAV approach provides an excellent backup when the ILS is

out of service, or for training purposes.

2- As the approaches are non-precision approaches, Thomson Airways currently requires a 2 miles

LEVEL segment to be flown before the FAF. We are currently reviewing our SOPs, but for the time

being, we ask that Cardiff ATC take this requirement into consideration when providing descent

clearances (Require 2 more track miles than an ILS CDA).

3- Because the FAF if a ‘Fly-Over’ waypoint, we are unable to accept clearances ‘direct to’ the FAF (As

this would not allow us to be established on the inbound course in order to commence descent). We

either require a clearance direct to the IAF or radar vectoring to a point no closer than 2nm before the

FAF.

4- The FAF altitude seems quite low/close to the RWY for RWY 30 (1600’). Thomson Airways would

prefer a higher FAF altitude of between 2000’ and 3000’. A lower FAF altitude (with the FAF closer to

the RWY) slightly increases the risk of an unstable approach (requiring a missed approach).

5.3.1 Responses to comments arising from no-objections

1 - Pilots would normally be vectored for an ILS approach. A pilot would be required to request an RNAV

approach if required. This will be included in the operational instruction relating to the use of an RNAV

Approach Procedure.

2- ATCOs are currently trained to provide a 2NM level segment preceding an ILS approach also. It is not

our intention to alter any current practices and therefore this requirement will be met.

3- Not withstanding this requirement will be included in the operation instruction relating to the use of an

RNAV Approach Procedure, the intention would always be to issue radar vectors followed by a clearance to

the IAF.

4- The FAF height indicated in the consultation document should be seen as a ‘lowest case’ example. The

procedures will be subject to flight validation ahead of their introduction to ensure that the FAF is suitable

for common aircraft which operate to Cardiff Airport.

5.4 Summary of intended Airspace Change Proposal

As a result of the careful consideration of all consultation responses, Cardiff International Airport Limited

intends to proceed to submit an Airspace Change Proposal (ACP) to the CAA. The basis of this proposal will be

for the introduction of new RNAV Approach procedures which replicate the existing conventional arrival tracks

as closely as possible (as described in the consultation document and below). This ACP will be considered by

the CAA and it is expected they will reach a decision during Summer 2015.

To allow for aircraft which are not yet RNAV equipped, the current conventional procedures will remain

available until such time as the aircraft RNAV equipage rate is close to 100%. The proposed implementation

date for the Approach procedures is Thursday 10th December. However, this is dependent on several factors,

including the CAA approval of the proposed change.

The consultation period for this airspace change proposal closed on 24th

February 2015. All responses submitted

before this date will be forwarded to the CAA Safety and Regulation Group (with personal details removed

where requested) who will consider the merits of the proposal.

If you have any further comments you may wish to make, these will still be accepted, and if they present new

evidence, may still influence the final airspace change proposal (see Section 6 for details on submitting further

responses).

5.5 Feedback to Consultees

This consultation feedback report will be made available to download on the Cardiff Airport website and an

email will be sent to all respondents directing them to the download page.

5.6 Post Implementation Review

Approximately twelve months after implementation of any airspace change, the sponsor (in this case Cardiff

International Airport Limited) will be expected to carry out a post-implementation review of the change to assess

and validate the success of the new arrangements. The purpose of the review will be to confirm that the RNAV

approaches are working as anticipated in the change proposal and have had the desired effect. The post-

implementation review also provides an opportunity to identify any unforeseen issues which may have arisen

and if so, address these.

This review is governed by the CAA CAP725 process and is conducted in conjunction with the CAA.

Cardiff International Airport Limited is committed to ensuring that any change represents the best possible

solution and takes into account concerns of consultees, operational constraints and the CAP725 legal framework.

6. Further Correspondence and Feedback

In the event that a representative organisation wishes to present new evidence or data to the Safety and Airspace

Regulation Group Director, for consideration prior to making his regulatory decision regarding this proposal, the

representative organisation must submit, in writing or via email, the information to the following address:

Head of Airspace Policy, Coordination & Consultation

Safety & Airspace Regulation Group,

CAA House,

45-49 Kingsway

London WC2B 6TE

Email: airspacepolicy@caa.co.uk

7. Consultation Emails & Web Text

7.1 Email sent to consultees at the start of the consultation

The following email was sent to consultees:

Please find attached to this email links in both Welsh and English to the consultation document for the proposed

introduction of Area Navigation (RNAV) approaches at Cardiff Airport

Within the document, it explains what RNAV approaches are, how you can respond and the timeframe to do so.

English http://www.cardiff-airport.com/cardiff-airport-rnav-consultation-document/

Welsh http://www.maesawyr-caerdydd.com/dogfen-ymgynghori-maes-awyr-caerdydd-rnav

Best regards

7.2 Cardiff Airport Web Landing Page Text

English

Cardiff Airport RNAV Consultation Document

The following consultation document describes the proposed introduction of a ‘GPS’ type approach to both

runways at Cardiff Airport which is based on where aircraft currently fly today. The document is available in

both the English and Welsh language in adobe acrobat format. If you require adobe acrobat reader it can be

downloaded here.

The consultation commences on 15th

December 2014 and completes on 20th

March 2015.

If you wish to respond to the consultation the details for responding are included at the bottom of the

downloaded document.

Click on the link below to download and view the RNAV consultation document

Download Cardiff Airport RNAV consultation document

Welsh

Dogfen ymgynghori Maes Awyr Caerdydd RNAV

Mae'r ddogfen ymgynghori ganlynol yn disgrifio bwriad i gyflwyno dull fath 'GPS' i'r ddau rhedfeydd Maes

Awyr Caerdydd sy'n seiliedig ar ble mae awyrennau yn hedfan ar hyn o bryd heddiw. Mae'r ddogfen ar gael

drwy gyfrwng y Gymraeg a Saesneg ar ffurf adobe acrobat. Os oes angen adobe acrobat reader gellir ei

lawrlwytho yma.

Mae'r ymgynghoriad yn dechrau ar 15 Rhagfyr 2014, a cwblhau ar 20 Mawrth at 2015.

Os hoffech ymateb i'r ymgynghoriad mae'r manylion ar gyfer ymateb yn cael eu cynnwys ar waelod y ddogfen.

Cliciwch isod i lawrlwytho'r ddogfen ymgynhori RNAV.

Lawrlwytho dogfen ymgynghori RNAV Maes Awyr Caerdydd

Appendices

Appendix A – List of consultees

A1 – Cardiff Airport Consultative Committee

The Cardiff Airport Consultative Committee includes representation from interested parties within the airport

(ABTA, Tourist Board etc.) and the following local government organisations:

Vale of Glamorgan Council

Rhondda Cynon Taff Council

Cardiff City Council

Bridgend Council

Llancarfan Community Council

Caerphilly County Council

Bristol City Council (Special Invite)

A2 – National Air Traffic Advisory Committee (NATMAC)

National Air Traffic Management Advisory Committee

Aviation Environment Federation

Airport Operators Association

Aircraft Owners & Pilots Association

British Airways

British Aerospace Systems

British Airline Pilots Association

British Air Transport Association

British Balloon & Airship Club

BBGA (Business & General Aviation)

British Gliding Association

British Hang Gliding & Paragliding Association

British Microlight Aircraft Association

British Model Flying Association

British Parachute Association

British Helicopter Association

Civil Aviation Authority

General Aviation Safety Council

Guild of Air Traffic Control Officers

Helicopter Club of Great Britain

Heathrow Airport Ltd

Heavy Airlines

Light Aircraft Association

Light Airlines

Low Fares Airlines

Ministry of Defence

NATS

PPL/IR

Unmanned Aerial Vehicles Association

UK Flight Safety Committee

A3 – Airlines

British Airways

EasyJet

KLM

Ryanair

Thomas Cook

Thomson

Virgin