Date : 12th August 2004

OPERATIONS IN CLASS D AND ATCO RELATIONS WITH THE GENERAL AVIATION COMMUNITY

In recent issues of Transmit we have reported on a number of issues that have arisen and that we had written to the CAA on those issues. We have received the following response. Our feeling was that this was a useful clarification of where CAA stands and we would agree with CAA that much of the solution is in your own hands and in the hands of the pilots concerned. We endorse the suggestions from CAA for better communication, intend to further contribute to that process and will be glad to publish articles from CAA that will help controllers to manage the task of controlling in Class D airspace.

1  Deteriorating Relationships between General Aviation (GA) Pilots and Controllers

The CAA shares the GATCO and GASCO (General Aviation Safety Council) concerns on the deterioration in the relationship between controllers and GA pi1ots. Indeed, this comment is backed up by evidence from the recent On-Track Report completed on behalf of the CAA by an independent team of consultants. The fol1ow-up work to the On- Track report is now underway through an expanded Airspace Infringements WG, co-chaired by John Hills (GAD) and Phil Roberts (DAP). While the AIWG already includes civil and military controller expertise, in addition to GA and military operators, GATCO representation would be welcome.  (We were delighted to receive this invitation and Neil Harris from East Midlands Airport is the new member of AIWG representing the Guild). 

In addition to carrying out its own responsibilities, the CAA would like to see GATCO do all that it can to educate its members on the requirements of GA pilots and, in particular, those who are inexperienced. Initiatives from local ATC units to visit, or host visits from local Clubs, Flying Schools or PFA Struts would help break down some of the barriers that exist. Furthermore, the CAA would positively welcome feedback from GATCO on any potential problem areas or hot spots that you might become aware of. 

2  Interpretation of Class D Rules by ATC Units

By permitting VFR flight to take place within Class D airspace, the CAA acknowledges that the rules are open to a degree of interpretation.  In many cases this works well and an efficient flow of all air traffic is maintained. Consequently, there is some reluctance to impose additional rules over and above the ICAO basic minimum requirement for fear of being unnecessarily prescriptive. Airspace is a national asset and is allocated to ATS providers to manage temporarily on a fair and equitable basis, having regard for the needs 

of all airspace users. What is unacceptable to the CAA is the adoption by the unit management of a policy that denies access to VFR transit traffic. We are monitoring some units closely and taking note of their crossing traffic statistics. In future, one element of the DAP approval of new Class D airspace will be the requirement to accommodate VFR traffic, whenever practically possible, and to keep records of transit services provided and refusals. 

Without doubt some of this is down to ATCO ethos, be it by unit, or even in some cases by individual watches. Where large numbers of refusals, or indeed infringements. are reported through the MOR process. CAA will look closely at the unit approach to transit traffic and seek to ensure that the rules and regulations are being applied. We are already doing this in a number of cases. From our perspective, the fact that this activity does not generate an income stream is not grounds on which to refuse the service. Protection of the (revenue earning) IFR traffic drives the need for Class D airspace in the first place and safely separating this from other itinerant GA traffic is part of the requirement. Equally, overly aggressive reporting quickly becomes evident in the statistics. 

3  Lack of Understanding of the Rules (Pilot and Controller)

Without doubt the rules can be seen by some as complex, although we would contend that they are adequately described in the MATS Pt 1 and JSP 552 (for controllers) and through the AIP, AICs and general GA articles (for pilots). Notwithstanding this, education is an ongoing progress and in response to the feedback from the On-Track Report and your comments, we will embark on a further round of education for pilots and control1ers. We consider that the assistance of GATCO in conducting this to be essential. We will use the safety evenings, articles in the GA press, a new Safety Sense Leaflet, GASIL and LASORS to get the message to the GA Community. Equally we will use the FODCOM process to address commercial operators who operate form airfields embedded within class D airspace. ATSINs, articles in controller magazines and. if necessary, amendments to MATS PT 1 will be used to target the controller population. As you may already be aware from your members we are attempting to harmonise the rules as applied by civil and military units. 

4  ATCO Training

ATSSD will raise this issue as a Hot Topic, a process that is used by that department to highlight issues to the Management of Air Traffic Service Provider (ATSP) Unit.  ATSPs will be asked to provide assurance that ATCO training, through unit training plans and the OJT processes, does not prejudice the equitable use of Class D airspace by the GA fraternity. The issue will also be placed on the agenda of the ATSSD Training Communication Group, an advisory body that encompasses training providers from the industry and representatives from different elements of the ATSP fraternity. 

5  CAA Differences in Interpretation

Perceptions are very difficult to address, however there is no difference in the policy as applied by DAP or SRG for the creation, or operation of Class D airspace. SRG staff are an essential part of the Case Consideration process of an airspace change proposal and ATSSD, GAD and indeed FOD, all share a common view on the utilisation of Class D.  We will ensure that staff in all areas conveys the same message in order to resolve any such misconceptions. There are without doubt differences in interpretation at units and it is not possible to monitor unit activity on a continuous basis. We use reporting mechanisms and incident reports to identify adverse trends and act upon them accordingly. 

6  Duty of Care

As regards the duty of care issue, this affects all of the parties involved in the operation of Class D or any other Class of airspace. The CAA has a duty to ensure that the rules applied in the UK are safe and appropriate, The pilot has a duty to ensure that he/she is appropriately qualified to fly inside CAS and is capable of flying within the limits of any clearance that is provided. Equally, the controller has responsibility to provide adequate information to the VFR pilot to ensure that he/she is capable of avoiding the IFR traffic. If there is any doubt as to this being possible then the controller should either refuse the clearance or provide a clearance which ensures adequate vertical or lateral deconf1iction, This happens at some Class D airfields by virtue of the selected crossing routes. 

7  Use of the 'Tyro' Prefix 

The CAA is of course aware of the tern TYRO and its use in a military context. However, we are unconvinced of the merit of introducing this on a unilateral basis from the civil training perspective. 

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