The consultation closes on the 3rd February 2020. Key points are set out below. We encourage you to make your own additional observations on the impact of these decisions.
The CAA consultation only enables comment on issues that have been missed, misunderstood or misrepresented. We have set out below key points that should be referenced in your response.
1. The consultation is not valid as most stakeholders are unaware of the Draft Decision. (Paragraph 33)
In para 33 the CAA state “In order to provide all stakeholders with the opportunity to comment…..”
The consultation has not been distributed widely nor has any effort been made by the CAA to inform those communities that will be impacted by this decision.
2. The Conventional SID which is being used to judge the RNAV-1 SID is not a valid comparison (Paragraph 1)
The 2019 Conventional SIDs are based on combined historical errors, using this as a benchmark for the measurement of this objective is totally unacceptable.
3. The 2019 Conventional SID which is being used to judge the RNAV-1 SID has not been the subject of a public consultation
Paragraph 14 states that the 2019 Conventional SID is now a permanent SID. How can this be so when there has been no CAP 1616 Airspace Change Process to validate that decision?
Annex A contains numerous statements from the CAA that a consultation is essential.
4. The CAA have failed to take proper account of the NPR when establishing the position of the 2019 conventional SID
CAP 1346, stated There should be an appropriate match between the SID and the NPR on Route 4 …..”
In para 29 of the Draft Decision the CAA say ……NPR alignment is a matter for GAL to agree with the DfT …..
The proposal detrimentally impacts communities outside of the NPR which cannot be right.
5. The Draft Decision takes no account of CAP1346 (Post Implementation Review of the Implementation of RNAV-1 SIDs at Gatwick) which was published in 2015
Example from Cap 1346 ….further south, further away from communities such as Leigh, Reigate and Redhill, that is more in line with where we expected traffic to be and as was the case prior to the introduction of the RNAV-1 SIDs….
The Draft Decision takes no account of the overlap with Route 3 or more densely populated communities. Following the introduction of Performance Navigation, Route 3 was shifted further north in a concentrated path. The proposals will overlap with Route 3 and impact the more densely populated areas of Reigate and Redhill. This is totally at odds with the objectives of the 2015 PIR.