Infringements – or what almost happened
The initial report and protracted subsequent responses and communications are published in précis due to lack of space. In summary, this report came to CHIRP in May 2022 and related to an airspace change involving the introduction of Class C airspace and changes to the vertical extent for the Daventry CTA and Clacton CTA. The reporter was from a flying school, and they had not been aware of the consultation for, or implementation of, the airspace changes (November 2021 and February 2022 respectively) due to the fact that they had not been flying over the period because of COVID/weather restrictions. By the time they had returned to flying in mid-March 2022, the associated NOTAM had been replaced by an AIC (AIC Y 006/2022) and the VFR chart had yet to be updated (the new Edition 48 Southern England and Wales 1/2mil map became available on 27th March).
The long and the short of it was that they got airborne unaware of the change, and it was only by good fortune that they did not infringe the new airspace. Setting aside the issue of personal and organisational responsibilities to check AICs etc when they returned to flying, with regard to airspace changes the reporter opines that the introduction of the ‘Luton Airspace’ change wasn’t very well communicated, and they suggest that any such changes should remain as active NOTAMs until after the publication of the associated revised VFR chart. More specifically, the reporter commented that, in their opinion:
It is second nature to start the day looking through the Met Office website and reading through the NOTAMS on the AIS website. The UK AIP is far too large a document to be comprehensively read before each flight; that’s why we have NOTAMS, or should have.When training in our local area, that’s most of our flights, we look at NOTAMs by selecting the Point PIB, typically with a radius of 25nm from our home base.
I have not been a part of the consultation on the new airspace and I would say that I look to my representative organisations, the British Microlight Aircraft Association (BMAA), the Aircraft Owners and Pilots Association (AOPA), and the Light Aircraft Association (LAA) to comment on behalf of their members. Flying schools have little in the way of resources to comment on the numerous and lengthy consultation documents produced.
Whilst on the topic of NATS promulgation of airspace information, NATS Briefing Sheets exist to cover events where they will occur at notice too short to be included in the AIRAC cycle. But the existence of Briefing Sheets is unknown to many GA pilots. Should a pilot be searching for Briefing Sheets on the NATS website they are not to be found under the expected heading of Briefings or the next logical heading of NOTAMS but under Publications.
Overall, the reporter said that the issue was one of communications and that their recommendations were:
- To publish a document, for example, a yellow AIC on a website and not tell us about it when we need to know, that’s on the day we do our flight planning, is not useful. The imposition of a new block of controlled airspace should be notified as a NOTAM from the date of inception until it has appeared in the new editions of the relevant maps for such time as is required for the GA community to know of its existence. If NATS are concerned about a proliferation of NOTAMs, I recommend they discontinue publishing those referring to Ethiopia, Ukraine etc; they appear for months on end and are of no relevance to a circle of 25nm radius around an airfield.
- The existence of Briefing Sheets and how to access them should be publicised throughout the GA community.
- The CAA should review their oversight of NATS communication of NOTAM information to GA.
- The CAA should consider engaging an advertising agency to define the methods and media and style to be used in communication; they are experts in putting a complicated concept into simple form appropriate to the target audiences.
The reporter also forwarded some of their comments to the BMAA, one of their representative associations.
The airspace change followed an extensive public consultation from October 2020 to February 2021, which received feedback from more than 2,400 respondents. Therefore, the potential for an airspace change was known about for a substantial period. The announcement by the CAA on 24 November 2021 through aviation forums was expected and it would be reasonable to expect those in the local area to review what had been approved by the CAA between the November announcement and the February implementation. It would appear the reporter did not do this as they were unaware of the announcement.
In addition to the publicity, the date for introducing the additional CAS was aligned with the monthly AIRAC cycle update, which is routine. On Feb 24th the relevant information was incorporated into the respective sections of the UK AIP. The information provided in the response is correct in that when a NOTAM search was conducted in March it would have limited information as the airspace change had been implemented into the UK AIP. It is assumed the reporter did not access the AIC between November and February, probably because they were unaware of the airspace change.
It should be noted the reporter refers to ‘Luton airspace’ on several occasions and concentrates on the Luton aspect of the NOTAM search. In fact, the airspace change was the introduction of Class C airspace and changes to the vertical extent for the Daventry CTA and Clacton CTA. It is true the airspace facilitates arrivals at Luton, but the airspace is not named as ‘Luton’ although Luton was referred to in the publicity. If the reporter had accessed the AIC, the airspace classification and boundaries may have become more apparent. The AIC referred to in the response was still available after Feb 24th.
The suggestion that all changes promulgated by NOTAMs should remain valid until a yearly chart update is impracticable. There is often extensive negative feedback and criticism around the number of NOTAMs provided to a pilot with when planning a flight, with comments such as not relevant or out-of-date. The proposal would make the number of NOTAMs valid before a new chart is published as vast and there would be a lot of negative feedback if this was introduced. It should be noted that electronic flight planning software producers update their products in line with the published AIRAC dates for this purpose.
As an organisation we signpost selected items of aviation news for our membership based on the widest applicability. We strongly encourage members to take personal responsibility for monitoring all other news items that may be relevant to their specific operation. The best and simplest way to do this is via the CAA SkyWise email service. However, we take note of the reporter’s comments, and we shall look at expanding our efforts with regards to airspace consultations in the future.
Although we have sympathy regarding the perennial problem of airspace changes sometimes not being reflected on VFR charts for some time after they are invoked, pilots and organisations have an individual responsibility to ensure that they use charts that are up-to-date with the latest chart amendment standard (as shown on the NATS AIP website in the ‘Charts’ section) before every flight. It is, however, acknowledged that there are often numerous amendments that are not always immediately obvious as to which part of the chart they apply.
With regard to communication of such changes, we agree that the current system appears to rely heavily on aviators ‘pulling’ information from websites rather than NATS/CAA persistently ‘pushing’ the fact that a change has been made. The CAA SkyWise notification system is a good start for initially highlighting a change, but it relies on people being subscribed and, whilst most flying clubs and organisations may well be, individual pilots may not. With respect to publishing NOTAMs that contain airspace change information until the next edition of the relevant VFR chart is published, CHIRP’s view is that this is probably not ideal given that NOTAMs can only be in place for 3 months and it could in extremis be up to a year before the associated VFR chart is updated – we don’t want to increase the number of NOTAMs in what is already a fairly user-unfriendly system.
But we do think that more should be done to provide an easily accessible resource that shows all airspace changes that have yet to be published on the VFR chart, along with NOTAM information. Currently, the Chart Amendments section on the NATS website provides a list of changes but a graphical interface that could be zoomed and localised to a particular area to show chart and other airspace information changes would be of great benefit to the aviation community as a briefing resource, as would a better user-guide on how to access and filter NOTAMs. CHIRP engaged with NATS on information promulgation and received some detailed responses that we don’t have space to reproduce here but which can be accessed on our website Hot Topics.
Key Issues relating to this report
Dirty Dozen Human Factors
The following ‘Dirty Dozen’ Human Factors elements were a key part of the CHIRP discussions about this report and are intended to provide food for thought when considering aspects that might be pertinent in similar circumstances.
Resources – poor NATS AIS website user interface
Awareness – the reporter was not aware of the airspace change
Knowledge – the information was available but not obtained
Communication – the NATS AIS system relies on users ‘pulling’ information by knowing where to look on the website; more pro-active and persistent publicising of changes using a graphical interface would help
Complacency – the reporter did not review the AICs before returning to flying after a long layoff