I put a response into the submission last week and got this response back from Apian:
"Thank you very much for responding with feedback on our proposal. We appreciate the time it has taken to read the material and the constructive feedback you have provided. We would be more than happy to meet and discuss this with you, but in the meantime, we have addressed your points below.
As previous air traffic controllers we have knowledge of and appreciate the restrictions you might face when flying, and getting a perspective from a pilot who flies in the local area is extremely important. Your feedback will help us continue the airspace change process by taking into consideration the feedback we have received to develop a more refined airspace.
Our intention is to work with the local GA community, including any local airfields or airstrips, to explore the possibility of operations working alongside each other. We, like the CAA and as I’m sure you do, believe that being able to share the airspace is ultimately the best solution for all stakeholders and this is a step along that path. We have previously successfully demonstrated working in close proximity to microgliding and gliding clubs, and believe we could work with you and the broader GA community to achieve the same in this trial.
Our proposal outlines the tops of the TDA must be represented in AMSL as accordance with ICAO Annex 11 2.30.2. Subject to approval, the UAS operator will be conducting operations below 600ft AGL, we will continue to evaluate the airspace requested for operations to ensure that the minimum airspace is being requested.
Your feedback regarding the DACS and DAAIS is also extremely helpful and we will continue to re-evaluate this requirement based on feedback from the aviation community and refinement of the proposed airspace.
Regarding NOTAMs in our previous trial, these were cancelled by the UAS operator directly when we did not anticipate flying. As per the NOTAM process, these were cancelled through the Airspace Regulation (Utilisation) Operations team at the CAA, who communicate them to the aviation industry. Cancellations of usage for the TDA were due to daily limitations (i.e. weather), which is why cancellations were not seen in advance as we utilised the TDA to complete as many deliveries, and capture as much data for the NHS as possible. Thank you for your suggestion of sharing more detailed utilisation, this is shared with the regulator on completion of the project. We will consider how best to share this with the GA and wider aviation community.
Current regulations mean that we are required to apply for a TDA, however, we would like to emphasise that we do not see this as a long-term solution and are working in collaboration with the CAA to support the development of integrated airspace that allows equitable use for all airspace users. Our UAS operator intends to seek CAA guidance on compliantly deploying detect and avoid technology to remove the need for segregated airspace, in line with the Airspace Modernisation Strategy.
We would like to thank you once again for your feedback, and confirm that this will be reviewed by our aviation team, and shared with the CAA as part of our submission."
The proposed "skygrab" is, in my view, disproportionate and the absence of a DACS / DAAIS is completely incogruent with effective and safe aviation activites in the North East.