Norwich airspace
I have just very briefly read bits of this consultation document, and it is an unmitigated disgrace.
Their executive summary is riddled with lies and fallacies:
"NIA... has become a major Regional Airport" - lie #1 - no it hasn't - it is a minor regional airport by any reasonable definition
"This Agreement effectively protected NIA traffic from military and other itinerant traffic operating in the vicinity" - fallacy #1 the "military traffic" from which NIA was protected has now gone with Coltishall's closure; lie #2 Coltishall never protected NIA from “itinerant” traffic as this was never obliged to receive any air traffic service; fallacy #2 they use a derogatory term to describe GA traffic (“itinerant” conjures images of vagrants) to support their argument
“Accordingly there has been a commensurate increase in ATC workload” - fallacy #3 - large amounts of airspace to control will also increase ATC workload
“...avoiding action and delaying action is commonplace which has been, on several occasions, to the general detriment of flight safety” - fallacy #4 - taking avoiding action is exactly about ensuring safety - it would be to the detriment of safety NOT to take avoiding action
Let me copy the final paragraph in full:
“NIA is an Air Navigation Service Provider (ANSP) approved under Article 100 of the Air
Navigation Order and, as such, must satisfy the UK Civil Aviation Authority (CAA) as to their
competence to provide air traffic services (ATS) and that the services are safe. In meeting
its statutory responsibilities for safety management of the ATS provided and in order to
assure an acceptable level of flight safety for aircraft inbound to or outbound from NIA in the
critical stages of flight, NIA proposes to submit a case to the CAA to establish Class D
controlled airspace in the vicinity of Norwich Airport.”
This is absolute drivel, and fallacy #5 - the logic of it is “we have a responsibility for safety therefore we need Class D airspace” - they have not submitted any relevant material in support of this assertion, instead just repeating the words “safe” or “safety” ad nauseam to browbeat the reader without submitting any evidence or reasoning - re-read the paragraph and count these words!
Someone suggested on another thread that there should be an airspace tax, whereby airports pay an annual amount per cubic mile of airspace they control - I think this is an exceptionally good idea, and it would make sure that airports don’t take any more airspace than they need. Also this concept is widely precedented - for example, in radio spectrum licensing fees (for e.g. mobile operators).
In short, this is an absolute disgrace. Whilst it won’t affect me personally, as a point of principle and to help our fellow aviators in East Anglia, I will be responding to the consultation in the strongest possible terms. I urge all others to do likewise.