More Controlled Airspace on the Way
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    More Controlled Airspace on the Way

    by mark » Sun Jul 18, 2021 11:43 am

    Hi all,

    The IAA has published their airspace change proposal for regional airports around the country as part of the Airspace Review announced earlier this year. The change will increase the size of control zones at the regional airports from a 10nm diameter circle to a 20nm x 20 nm square control zone. The control areas (aka the stubs) will now be increased in size from the existing 10nm x 10nm dimensions to 10nm x 20nm.

    Of the 33 submissions and 276 comments made, 0 were accepted and only 4 were partially accepted.

    The Review of Irish Airspace (including the Airspace Change Proposal) can be viewed here.

    And the IAA's response to comments can be viewed here.

    Personally, I'm shocked at the way in which all of the comments have been disregarded but I would be interested in hearing others opinion on this.

    Regards,
    Mark
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    Re: More Controlled Airspace on the Way

    by hum » Sun Jul 18, 2021 12:47 pm

    Hugely disappointing, appears to have almost completely ignored the 'consultation' process and responses.

    Regional zones transformed from circles to squares, thereby increasing their footprint from 314.2 sq nm to 400 sq nm.

    Completely ignored multiple pleas to reduce size and shape of Shannon & Cork zones.

    The 'gap' that was already narrow between Knock and Sligo has closed up.

    Incredible
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    Re: More Controlled Airspace on the Way

    by ois » Sun Jul 18, 2021 1:36 pm

    What a disappointing read. I think the major thing that sticks out is the Sligo/Connaught zones. It was pointed out to the IAA ANSP that the gap between the two needed to be widened as it's narrow and has/could lead to airprox incidents between aircraft trying to avoid controlled airspace. They've now tightened the gap. How any sane person could design, review and publish that design is beyond me...

    The major extension of CAS in the EINN/EICK/EIKY area is ridiculous and will be a hindrance to GA activity.

    Comments are invited until the 12th of August, is it worth submitting comments if they clearly don't read them?!
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    Re: More Controlled Airspace on the Way

    by OnTheNumbers » Sun Jul 18, 2021 10:06 pm

    It is incredibly disappointing and proposal and seems to have taken no account of GA stakeholders input.

    During the consultative process much was made of the priniciple of "not wanting to control airspace that doesn't need to be controlled" - it seems designers' definition of what needs to be controlled is at odds with GA stakeholders perception.

    Is this really the best we can do in terms of re-imagining airspace design?
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    Re: More Controlled Airspace on the Way

    by Technerdian » Tue Jul 20, 2021 2:09 pm

    Hi All,

    Having ignored our "submissions" we are now asked for "consultation" on the design. This is of course a box ticking effort by the IAA so they can claim there was a "consultation period" in compliance with regulations. However, if we don't make any comment during this consultation period, they will use that as justification to charge ahead and be able to show the Minister and others that "there was no input during the consultation period".

    I will submit comments during the consultation, which will largely be a reiteration of my earlier ones. Two of those were supposedly "partially accepted" with no indication of which part and what effect resulted from accepting those parts! I expect others will similarly repeat their submissions. However, I think a coordinated response from multiple people and the various organizations: GASCI, ILAS, NMAI etc. will demonstrate that the GA community as a whole is opposed to this expansion of controlled airspace. At the very least it will provide something substantial to send to TDs demonstrating this is an issue for the whole GA community.

    If we don't push back against this expansion of airspace we will spend the next several years moaning about how ridiculous Irish airspace is and how ATC for GA is a joke compared to mainland Europe, and how the IAA got away with showing utter disrespect for the GA community, and so on. If we don't take action now, then we deserve any restrictions that result any such complaining will be pointless.

    I'm willing to help, but I'm new to aviation and I don't know who's who!

    To start a conversation:
    • Is a coordinated submission from multiple organizations a good way to go? (This does NOT preclude people making their own in addition).
    • How do we get these organizations and others together to create coordinated submissions (or perhaps a combined submission)?
    • Can we get agreement in the community on a submission that many would support?
    I'd love to see an open letter and consultation response go into the IAA with several hundred signatures!

    How about a general meeting - maybe outdoors (COVID-safe) at one of the larger airfields?
    At the very least a Zoom (where people can talk, rather than the Teams effort where IAA controls the conversation)?

    Is there any appetite to push back?

    Regards,

    Gareth.
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    Re: More Controlled Airspace on the Way

    by Peter Gorman » Tue Jul 20, 2021 7:11 pm

    After all the honeyed words about consulting users, and reducing unnecessary CAS, for regionals all we get is rectangles where there were circles, and bigger stubs. So 20 nm CTRs of 314 nm^2 become 400 nm^2, and each CTA stub roughly doubled from 100 to 200 nm^2. So for say EIWF alone that would be 280 nm^2 extra CAS. Someone might like to calculate how many cubic miles of extra CAS is coming down the track.

    The great majority of comments were dismissed with "noted".

    My own complaint that the AIP provisions for filing flight plans are inconsistent with SERA was "noted" and passed on to someone in the IAA. There it will presumably be binned as implementation as easier GA access to CAS might involve resources i.e. money.

    Does anyone know how one can make a complaint (to EASA?) about failure to implement a rule in SERA?
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    Re: More Controlled Airspace on the Way

    by Papa8 » Wed Jul 28, 2021 12:01 am

    I read all the submissions and thought some very good points were made. Suggestions such as a better East-West VFR transit and the current problems with the Lambay transit were probably outside the scope of what was being reviewed this time but staying optimistic it might open up the discussion if the drum is banged again in this manner when the opportunity arises. There were numerous points made for example on maintaining or increasing the ceiling of G airspace in the Shannon FIR. Am I correct to say that the threat to lower it to 4500ft is now off the agenda? Notwithstanding the additional CAS that will arise in CTRs (and their CTA stubs) and the requests to shave off the non-runway-aligned portions of CTRs being ignored there is a need to remain balanced in looking at what has occurred with Irish airspace. I know you could go back to the beginning of aviation and point out how airspace was not controlled as much as it is today but I took a look, at least, at an old 1:500k chart I had from about 2002. At that point you had MOAs extending from Gormanston, the Gormanston aerodrome’s airspace with panhandles itself, R20 from SFC to 2000ft, Galway CTR and its panhandles, MOA 5 extending past Nenagh and the prohibited airspace over South Armagh still in force. P10 over the Curragh Camp was bigger too. With the planned revisions I think we are also gaining some extra Class G (up to FL75) around the Burren and Inisheer for example. Some airspace changes are over water which won’t be noticed. I still feel GA should use our voice where it needs to be heard but we should keep these airspace revisions within the overall context of the past twenty years as there have been gains made for us by the IAA as well as losses.

    And we have many things to make known, I want to see glider and free-air pilots able to achieve height and cross-country goals which is not infringed more hopefully. I would love the suggestions for R15 to be adopted (certainly to hear what the issues would be in trying to accommodate it anyway), the traffic safety systems for airspace in a format that a hang-glider pilot could reasonably implement, EIWT to revert properly to Class G if there is no controller in the tower etc. I noticed too that Ireland West would like to see GA have, I guess, what amounts to a Class G corridor presumably in the vicinity of the high ground for non-transponder aircraft to transit in uncontrolled airspace. The arrival of more UAVs/drones also needs to be accommodated into our airspace and welcomed as a growing aviation sport and profession. I think perhaps greater feedback from the relevant parties inside the IAA of our personal expectations/preferences for airspace to reduce GA pilot workload and an improvement in safety for us could be reflected back with more detail as to the issues involved than a mere ‘noted’ and passed on as others have said. I think the people who receive the submissions and presumably sit at meetings on this topic should have an in-built detailed response deadline when a public submission/consultation is sought just like we had one when we were asked to discuss the topic. And I don’t mean a column with one boilerplate sentence. There are many voices and competing interests at stake with these kind of changes and so making specific replies to our suggestions publicly might lead to another competing interest raising themselves above the parapet leading to further discontent etc. But there are ways to do this still with at least some detail for us to digest - for example a FAQ-style response to the general category of question we have made. E.g. Why was smaller CTR controlled airspace (akin to the size/area of Stansted) not an option for EICK/EINN? And then you have an written answer in detail on that. That sort of thing. Rational decisions are more palatable even if we disagree than the appearance of being stone-walled (and I don’t think there was any intention of stone-walling or steam-rolling through changes) I think it was bona-fide to get our opinions in the first place but if the questions are going to be asked then it is only fair that we hear in a reasonable way what was the result of discussions from this. Would there be minutes that could be partially released I wonder or is it too sensitive?
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    Re: More Controlled Airspace on the Way

    by mark » Wed Jul 28, 2021 5:32 pm

    Unbelievable...no other words to describe that webinar this afternoon...
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    Re: More Controlled Airspace on the Way

    by ois » Wed Jul 28, 2021 10:11 pm

    I couldn't make it to the teams meeting today but it doesn't sound like I missed much. Any explanation on the square zones other than "it's to protect IFPs"?

    I heard a representative of the IAA (Regulator) was telling people not to speak out of turn, making them mute and virtually put their "hand up" if they wanted to speak. If this is true, they are only reinforcing our belief that what we say doesn't really matter! Shambles :roll:
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    Re: More Controlled Airspace on the Way

    by Pilot » Wed Jul 28, 2021 11:25 pm

    ois wrote: Wed Jul 28, 2021 10:11 pm Any explanation on the square zones other than "it's to protect IFPs
    Yes! But you won't believe what the explaination was! (Well maybe you will!)

    Mark asked what the justification was for expanding the circles into squares. The answer, very clearly was given as "The GA community said that they thought the circles were old and that they should be squares. So we decided to show what they would look like as squares!"

    Mark, agasht like the rest of us on the call, basically ask if he had heard them correctly and that the only justification was "to show us what square CTRs look like" and they confirmed that that was the only justification! We were told to object if we don't like it.

    Of course people had said that the CTRs should be square, but as in circles squared off inside the circle! Not circles expanded into rectangles.

    Other interesting points to come out were
    - that the justification for not considering any class of airspace beyond C or E was based on a task force that was abandoned in 2009!
    - They mentioned that class E CTRs are not allowed by EASA, but failed to mention that nobody was asking for class E CTRs, only CTAs!
    - the IAA insist tha the CTRs must include the SIDs/STARS and missed approach paths for all IFR approachs (NDB, DME, ILS and GPS). But there is no push back from the IAA on how much area these take up. So if a regional airport makes an approach proceedure based on an NDB that makes huge big circles then that is fine even though they could be much tighter, and the CTR must be made wide enough to cover that + 3nm. "Build it and we'll give you the airspace" seems to be the mantra. Basically as one commenter put it, the tail is wagging the dog.
    - It was pointed out that while the original consultation was proposed to assist airlnes make continuous descent and climb operations, no airline had responded to the consultation supporting it. They were asked if no airline is supporring it, and it's for their benefit, then why is it proceeding? Now they are justying it on the basis of being forced to support these operations by EASA even if the airlines aren't pushing for it.
    - It was asked why none of the current circular CTRs could be tightened in or corners cut off, and the contributor was (rudely in my opinion) told to go and hire their own planning consultants to design new proceedures and submit that as an airspace proposal!
    - They plan to increase the airspace now, but are expecting that by 2030 (just 9 years away) that they'll have to start removing some of it again as navaids and their related proceedures are withdrawn! (I suspect this was more intended as a "Don't worry about giving up the class G now. You'll get most of it back in a few years" type of argument, that will fail to materialise).
    - General points will not be all that helpful in the consultation. If you want to make a suggestion then you need to explicedly state which CTR/CTA you think should be changed and in which area and which way. Not a more general comment on how to reduce CTR sizes but list each one and which side/space you'd remove and why.

    I've had a very positive view of the IAA in the past. Obviously not perfect, but I've always thought that they were a pretty decent regulator. In my other dealings, I've found the host today is a decent and pleasant man, and I found the ATC guy who made the first series of briefings (also involved today) to come across as an honest and fair minded person.

    But this briefing today was very unprofessional, very biased and really unbecommig of the authority. To be frank, if it wasn't a public body but a private company, then there would be very difficult conversations tomorrow between this team and the big bosses. I doubt that will happen in the IAA.

    But if nothing else, they at least got a pretty solid view of how GA sees their proposals. If nothing else, at least they know that we are not all signing off the same hymn sheet and the GA community is not very impressed with their work.
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    Re: More Controlled Airspace on the Way

    by Pilot » Wed Jul 28, 2021 11:38 pm

    ois wrote: Wed Jul 28, 2021 10:11 pm I heard a representative of the IAA (Regulator) was telling people not to speak out of turn, making them mute and virtually put their "hand up" if they wanted to speak. If this is true, they are only reinforcing our belief that what we say doesn't really matter!
    I should say that I think that part was fair enough. Everyone wanted to have their say at the right moment, but if we all spoke as soon as we heared something that we disagreed with, then the call would have descended into a screaming match with nobody actually being heard. Everyone who wanted to speak indicated that by raising a virtual hand, and they got the opportunity to speak in their turn. That's fair enough in my mind. (I think there was one lady who had her hand up at the end who didn't get to speak, but everyone else I think got to speak).
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    Re: More Controlled Airspace on the Way

    by mark » Fri Jul 30, 2021 11:19 pm

    Hi Pilot,

    I think your points were very well made too on the call as were most others. I've been inundated with texts, calls and emails about what to do next. Any suggestions?

    I feel like I shouldn't bother writing another submission after everything in my last one was ignored! Would there be any appetite for a group Zoom / Teams call to discuss further. It looks like we're all singing from the same hymn sheet so maybe a joint detailed submission from a group of people might be more effective than multiple, less detailed submissions.

    Regards,
    Mark
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    Re: More Controlled Airspace on the Way

    by Pilot » Sat Jul 31, 2021 11:39 am

    I'm happy to meetup for a Team/Zoom call. We don't have a lot of time, but I'm happy to do so.

    I also agree with the idea of a 'joint response' but think it's also important that we make our individual responses too. One issue that is in the IAA's favour is that so few pilots responded initially. There were only 33 responses and some of those were from ATC. So less than 30 pilots responded out of the 4K PPLs in Ireland. It's easy for them to frame it as 'there was no wisespread opposition'.

    So numbers of replies are important too, even if they are just saying the same thing in a slightly different way. It's also important that the widespread opposition is recorded officially, so that after the event appeals could be made to other authorities if necessary showing that feedback wasn't properly taken account of.

    I noticed in your reply to the original consultaiton that you made an excellent point about Sligo and Waterford not having any scheduled traffic. They essentially dismissed that on the basis that they were required to make provision for CBO/CDO for environmental reasons (after it was pointed out that the airlines aren't supporting the proposals, so it can't be for their benefit).

    That got me thinking. What is the environmental impact on Sligo & Waterford? Given the lack of schedule airline traffic, I would think that very few flights would benefit from the CCO/CDO. The main user of the approaches is probably the based S&R helis. For them to benefit, it would have to be a day with IMC conditions so VFR wasn't available to them (I'm sure they prefer to fly a visual approach to save time normally). They would also have to be flying high enough that a continious descent would need to start outside the CTR (ie more than 3K feet at least). And they would need to be approaching from an angle that the current stubbs would not faciliate the descent/climb.

    I imagine that such flights would not be all that common. So the fuel saving would not be that frequent.
    Yet lots of GA fuel will be spent everyday going around the stubbs and expanded CTRs.

    It would seem to me, that in at least the case of EISG and EIWF, that the proposals will cost more fuel to the fleet than will be saved, and as such the environmental impact will be negative. The exact opposite of what they are trying to achieve.
    I'm not so sure about EIDL and EIKY, but can't imagine that it's a clear cut case of fuel saving in their cases either.

    That says to me, that there is a real need for the IAA to do an environmental impact study rather than assuming that this will have a positive impact on the environment. They might end up harming the environment rather than helping it.

    We should also find the regulating that they are saying is forcing them to do this, and make sure that it does in fact say that, and that they aren't misreading it (or reading it the way that they want to read it).
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    Re: More Controlled Airspace on the Way

    by Simon » Sat Aug 07, 2021 2:04 pm

    mark wrote: Fri Jul 30, 2021 11:19 pm Would there be any appetite for a group Zoom / Teams call to discuss further.
    I would be.

    I only got the tail end of the teams with the IAA, and appreciate Mark speaking for us.

    If it is just numbers they are looking at and not reason, we could organize more pilots to reply in objection.
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    Re: More Controlled Airspace on the Way

    by mark » Sat Aug 07, 2021 9:22 pm

    Hi all,

    Zoom is organised for 7pm on Monday evening. I've emailed many of you on this thread with details of the login. If anyone else is interested in joining please contact me at mark@flyinginireland.com

    Regards,
    Mark

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