Its not dealing with the problem
Looking through the document it appears to me that Norwich is arguing that it is necessary to have controlled airspace primarily to protect its incoming and outgoing routes from conflicting with military traffic.
If the problem is inadequate co-ordination with military aviation then surely this is what they should be addressing rather than trying to take control themselves of all the local airspace around the airport. It states that they have tried to co-ordinate with the military but have not been able to establish any agreement that will resolve the problem. Unfortunately, it is not clear what they attempted and why it was not successful. Simply stating in para 5.4 that the problem military traffic is not locally controlled but managed centrally through the MoD, or by an on station AWAC not in contact with Norwich ATC, does not I feel adequately answer this point.
The significant impact on the implementation of an additional large control zone on the recreational aviation that takes place in East Anglia is not well developed and elaborated in this document. The impact on costs and customer experience for recreational operators of the additional levels of organizational complexity created by the proposal are not well thought through or explained. While recognizing that recreational aviation takes place on local airfields the limit of their response is to state that a letter of agreement or MoU will be put in place and that they will provide transit through their area of control when it is reasonable to do so. The difficulty with these and other good will statements in the document is the lack of any quantified performance measures for what Norwich means by reasonable or that commit Norwich to a minimum quality of service for recreational and other GA traffic.
I would have been more impressed with a clear commitment to developing local recreational aviation and Norwich as the East Anglian destination of choice for recreational and GA pilots and some clear statement about what they will do to achieve this. For example some Scottish airfields offer weekend deals on landings and parking - £30 for the weekend and as many landings as you want. No sign of this kind of thinking in this proposal document.
To offset the considerable costs that Norwich’s proposal will cause the recreational community some attempt could have been made to control costs for GA people flying into Norwich. A simple performance measure could have been given such as fixing the total price for visiting Norwich in typical spam can at no more than the median cost of a landing at any East Anglian ICAO airfield. A similar approach could be taken to parking with again the cost being kept at or below the median for East Anglia. This could have been integrated with a commitment to much better marketing and communications into the recreational and wider GA community through its www site and other routes.
Since safety lies at the root of this proposal this may also offer an opportunity for Norwich to improve the value of the proposal to the wider community that are losing access to the airspace they wish to take control of. A simple metric for this could be 6 ATC safety weekends per year where Norwich invites recreational flyers come on in and practice their skills at instrument approaches and other ATC procedures at a token cost. This could have additional community impact if Norwich donated the token charges from the recreational pilots to charities such as GASGO or to support the Fly-On-Track www site and/or RAFA, British Disabled Flying Association . . . etc.
Generally, in the UK I think a lot more proactive work needs to be done by ATC controlled airfields to get recreational GA using them. It should be easier and cheaper for a recreational GA pilot to take his or her family shopping in towns with a good airfield such as Norwich by flying in rather than by adding to the congestion on the roads and trains. Also, from a safety perspective frequent and easy access to the airport and its ATC procedures will build confidence and, I believe, increase a pilot’s willingness to talk to the ATC unit when in the local area.