Walney Extension Offshore Wind Farm TMZ Final Report on the Stakeholder Consultation ·...
Transcript of Walney Extension Offshore Wind Farm TMZ Final Report on the Stakeholder Consultation ·...
Date: 30 January 2015
Revision: Issue 1
Osprey Ref: 70791 020
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Walney Extension Offshore Wind Farm TMZ – Final Report on the Stakeholder Consultation
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Document Details
Reference Description
Document Title Walney Extension Offshore Wind Farm TMZ – Final Report on the Stakeholder Consultation
Document Ref 70791 020
Issue Issue 1
Date 30 January 2015
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Executive Summary
DONG Energy is the Sponsor for a proposed airspace change over the existing operational Walney Offshore Wind Farms (1 and 2), the Walney Extension Offshore Wind Farm, West of Duddon Sands (WoDS), Ormonde and Barrow Wind Farms, located northwest of Morecambe Bay in the Irish Sea.
As part of the Civil Aviation Authority’s (CAA) Airspace Change Process (ACP)(CAP 725) [Reference 1], DONG Energy is required to submit a case to the CAA to justify the establishment of a Transponder Mandatory Zone (TMZ) over the existing Walney, WoDS, Ormonde and Barrow Wind Farms and the Walney Extension Offshore Wind Farm, and to undertake a consultation exercise with all relevant stakeholders. This ensures that all stakeholders who may be affected directly or indirectly by the proposed change are consulted, as well as highlighting any environmental impacts that the proposed airspace change may have.
DONG Energy has engaged Osprey Consulting Services Ltd (Osprey) to project manage the ACP on their behalf.
This document is a Final Report on the consultation carried out by DONG Energy between 10th October 2014 and 11th January 2015 in accordance with the requirements of CAA CAP 725 [Reference 1]. It includes an analysis of all submissions received throughout the consultation and identifies the main issues raised by consultees. It also provides DONG Energy’s views in relation to the issues raised and outlines post-consultation action taken, or planned to be undertaken by DONG Energy.
This document will form part of the Airspace Change Proposal submission to the CAA that will detail the case for the proposed TMZ.
Subject of the Consultation
The purpose of this consultation was to gather and analyse the views of the various stakeholders concerning a proposal to establish a TMZ over the existing Walney Wind Farms and the Walney Extension Offshore Wind Farm in Morecambe Bay. Fundamentally, the aim of the consultation was to enable DONG Energy to obtain or confirm views and opinions about the impact of the proposed airspace change.
Consultees
The Consultation Document was circulated to a total of 72 consultee organisations or individuals; of these three emails were returned as undelivered. The aviation consultees included aviation parties such as the Ministry of Defence (MOD), airlines, aircraft operators, adjacent aerodromes, all local airspace users and the national bodies representing all UK aviation interests who may be affected by the regulatory requirements within the TMZ. National bodies such as LAA, BALPA, AOA etc. are represented through the auspices of the National Air Traffic Management Advisory Committee (NATMAC), sponsored by the CAA. A number of military organisations are also members of the NATMAC.
Non-aviation stakeholders for consultation included environmental and heritage organisations, local planning authorities and the general public. Although the proposed change to the airspace
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lies offshore, and there are no changes to the way aircraft operate over land, the neighbouring coastal districts and parish councils were also consulted. The views of individual members of the public were also welcomed.
Consultation Statistics
A total of ten responses (approximately 15 % of consultees) to the consultation were received, from a total of 69 consultees.
Of these, two consultees (20 %) supported the proposal to establish a TMZ over the Morecambe Bay Offshore Wind Farms; six consultees (60 %) provided a neutral response, whereby the consultee did not object or provided no comments on the proposal; and one consultee (10 %) objected to the proposal.
One consultee raised other comments relating to the presence of the Walney Extension Offshore Wind Farm and not to the development of the Walney TMZ. Such comments have therefore not been included in the analysis.
Next Stages of the ACP
The consultation process constitutes the third stage of the CAA’s overall process laid down in CAP 725 [Reference 1] leading to an Airspace Change Proposal.
DONG Energy will submit a formal Airspace Change Proposal to the Airspace Regulation (AR) of the CAA detailing the case for the proposed TMZ. It is a requirement of the consultation process that DONG Energy will provide the CAA with full details of the consultation (including copies of responses and correspondence) together with all documentation necessary for the promulgation of the proposed TMZ. Following receipt of the formal Airspace Change Proposal, the CAA then requires a 16-week period to conduct its own internal analysis of the final proposal and consultation results, before arriving at a Regulatory Decision.
Should the CAA, without the need for further design optimisation or analysis, accept the Airspace Change Proposal, DONG Energy suggest that the implementation of the TMZ would take place on a single date to coincide with the initial operational date of the Walney Extension Offshore Wind Farm, expected to be in mid-2017.
DONG Energy extend their thanks to all consultees and other individuals who took their time to participate in this consultation and for their very useful feedback.
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Contents
1 Glossary ......................................................................................................................................... 7
2 Introduction ............................................................................................................................... 11
2.1 General ......................................................................................................................................................... 11 2.2 Subject of the Consultation ................................................................................................................. 11 2.3 Development of the Consultee List .................................................................................................. 12 2.4 Confidentiality .......................................................................................................................................... 12 2.5 Document structure ............................................................................................................................... 13
3 Consultation Statistics ............................................................................................................ 14
3.1 Introduction .............................................................................................................................................. 14 3.2 Consultee Organisations....................................................................................................................... 14 3.3 Responses ................................................................................................................................................... 15 3.4 Meetings with Major Stakeholders .................................................................................................. 16
4 Analysis of Responses ............................................................................................................. 17
4.1 Introduction .............................................................................................................................................. 17 4.2 Response Support Ratio ....................................................................................................................... 17 4.3 Key Issues arising from Consultee Responses ............................................................................ 18 4.4 Objection ..................................................................................................................................................... 19 4.5 Isle of Man Airport PSR Concerns .................................................................................................... 19
5 Post-Consultation Actions ..................................................................................................... 20
5.1 Post-Consultation Review ................................................................................................................... 20 5.2 DONG Energy Conclusions .................................................................................................................. 20 5.3 Next Stages of the ACP .......................................................................................................................... 20
6 References .................................................................................................................................. 21
A1 Consultation Background and Methodology .................................................................. 22
A1.1 Background to the Consultation ........................................................................................................ 22 A1.2 Method of Consultation ......................................................................................................................... 22
A2 Stakeholder / Consultee List ................................................................................................ 24
A2.1 Aviation Consultees: Aerodromes / Local Aviation Consultees ........................................... 24 A2.2 Aviation Consultees: National Organisations (NATMAC) ....................................................... 24 A2.3 Non-Aviation Consultees: National Bodies ................................................................................... 26 A2.4 Non-Aviation Consultees: Regional Council Authorities ......................................................... 26 A2.5 Non-Aviation Consultees: Regional Council Authorities ......................................................... 27
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A2.6 Information Organisations: Members of Parliament ................................................................ 28 A2.7 Information Organisations: Civil Aviation Authority ................................................................ 28
A3 Key Issues arising from the Consultation ........................................................................ 29
Table of Figures
Figure 1 Distribution of Consultees ....................................................................................................................... 15 Figure 2 Responses from Listed Consultees ....................................................................................................... 16 Figure 3 Support Ratio from Listed Consultees ................................................................................................ 18
Table of Tables
Table 1 Responses from Consultees ...................................................................................................................... 15 Table 2 Pre-Consultation Stakeholder Meetings .............................................................................................. 16
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1 Glossary
Acronym Meaning
ACC Airport Consultative Committee
ACP Airspace Change Process
ACAS Airborne Collision Avoidance System
AEF Air Experience Flight
agl Above ground level
AIP Aeronautical Information Publication
AOA Airport Operators Association
AOPA Aircraft Owners and Pilots Association
AR Airspace Regulation
ARA Advisory Radio Area
ARPAS Association of Remotely Piloted Aircraft Systems
ASL Above Sea Level
ATC Air Traffic Control
ATM Air Traffic Management
ATSOCAS Air Traffic Service Outside Controlled Airspace
ATS Air Traffic Service
ATSU Air Traffic Service Unit
BAA British Airports Association
BABO British Association of Balloon Operators
BALPA British Airline Pilots’ Association
BATA British Air Transport Association
BBAC British Balloon and Airship Club
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BBGA British Business and General Aviation Association
BGA British Gliding Association
BHA British Helicopter Association
BHPA British Hand Gliding and Paragliding Association
BIA Blackpool International Airport
BMAA British Microlight Aircraft Association
BMFA British Model Flying Association
BPA British Parachute Association
CAA Civil Aviation Authority
CAP Civil Aviation Authority Aeronautical Publication
CAS Controlled Airspace
CAT Commercial Air Transport
CHA Chester Hawarden Airport
CTA Control Area (Class D UK Airspace)
DAATM Defence Airspace and Air Traffic Management
DAP Directorate of Airspace Policy (part of the CAA – now SARG)
DfT Department for Transport
DS Deconfliction Service
ELFAA European Low Fares Airline Association
FL Flight Level
GA General Aviation
GASCo General Aviation Safety Council
GAT General Air Traffic
GAPAN Guild of Air Pilots and Air Navigators
GATCO Guild of Air Traffic Control Officers
HCGB Helicopter Club of Great Britain
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HQ DAAvn Headquarters Director Army Aviation
HTZ Helicopter Traffic Zone
IAIP Integrated Aeronautical Information Package
IFP Instrument Flight Procedure
IoMA Isle of Man Airport
LAA Light Aircraft Association
LARS Lower Airspace Radar Service
LJLA Liverpool John Lennon Airport
LoA Letter of Agreement
MAA Military Aviation Authority
MOD Ministry of Defence
MP Member of Parliament
NATMAC National Air Traffic Management Advisory Committee
NATS The National Air Traffic Service Provider
NERL NATS En-Route Ltd
NCHQ Navy Command Head Quarters
NM Nautical Miles
OS Ordnance Survey
PINS Planning Inspectorate
PSR Primary Surveillance Radar
RAF Royal Air Force
SARG CAA Safety and Airspace Regulation Group
SRG Safety Regulation Group (part of the CAA)
SSR Secondary Surveillance Radar
TMZ Transponder (SSR) Mandatory Zone
UAS University Air Squadron
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UAV Unmanned Air Vehicles
UKAB UK Airprox Board
UKFSC UK Flight Safety Committee
VGS Volunteer Gliding Squadron
VOR VHF Omni Directional Radio Range; a type of short-range radio navigation system for aircraft
WAL Wallasey VOR
WoDS West of Duddon Sands
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2 Introduction
This document is the Final Report of the consultation, carried out by DONG Energy between 10th October 2014 and 11th January 2015, on the establishment of a Transponder Mandatory Zone (TMZ) over the existing Walney (1 and 2) Offshore Wind Farms, the Walney Extension Offshore Wind Farm, West of Duddon Sands (WoDS), Ormonde and Barrow Wind Farms. The aim of this report is to present details on the statistical data arising from the responses to the consultation, together with an analysis of the feedback received.
2.1 General
DONG Energy is the Sponsor for a proposed airspace change over the existing Walney (1 and 2) Offshore Wind Farms, the Walney Extension Offshore Wind Farm, West of Duddon Sands (WoDS), Ormonde and Barrow Wind Farms to the northwest of Morecambe Bay in the Irish Sea.
As part of the Civil Aviation Authority’s (CAA) Airspace Change Process (ACP)(CAP 725) [Reference 1], DONG Energy is required to submit a case to the CAA to justify the establishment of a Transponder Mandatory Zone (TMZ) over the existing Walney, WoDS, Ormonde and Barrow Wind Farms and the Walney Extension Offshore Wind Farm, and to undertake a consultation exercise with all relevant stakeholders. This ensures that all stakeholders who may be affected directly or indirectly by the proposed change are consulted, as well as highlighting any environmental impacts that the proposed airspace change may have.
DONG Energy has engaged Osprey Consulting Services Ltd (Osprey) to project manage the ACP on their behalf. The Walney TMZ airspace change is hereafter referred to as ‘the proposal’.
This document is the Final Report on the consultation carried out by DONG Energy between 10th October 2014 and 11th January 2015. The background to the consultation and the methodology used are detailed in Annex A1 to this document. The aim of this report is to present details on the statistical data arising from the responses to the consultation, together with an analysis of the feedback received.
DONG Energy would like to thank all consultees and other individuals who took the time to participate in this consultation and for their very useful feedback.
2.2 Subject of the Consultation
The purpose of this consultation was to gather and analyse the views of the various stakeholders concerning a proposal to establish a TMZ over the existing Walney (1 and 2), the Walney Extension Offshore Wind Farm, WoDS, Ormonde and Barrow Wind Farms in Morecambe Bay. Fundamentally, the consultation will enable DONG Energy to obtain or confirm views and opinions about the impact of the proposed airspace change.
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The proposed establishment of the TMZ is one element of a three-part Mitigation Package aimed at negating the impact of the clutter from the Walney Extension Offshore Wind Farm wind turbines upon the Warton Primary Surveillance Radar (PSR). The three parts are:
Element 1: Establishment of a TMZ; Element 2: Authorisation to control Secondary Surveillance Radar (SSR)-only
and; Element 3: Suppression of PSR returns within the boundary of the Wind
Farms.
Such an airspace change is necessary in order to mitigate the effects of the wind turbines on the Warton PSR. This will ensure that a full suite of Air Traffic Service Outside Controlled Airspace (ATSOCAS)1 can continue to be provided, whilst maintaining the current levels of airspace effectiveness and efficiency in this area.
This consultation is not about facilitating change of routine air traffic procedures at local aerodromes.
2.3 Development of the Consultee List
A full list of consultees was developed with the advice of the CAA and is given at Annex A2.
At the start of the consultation, DONG Energy sent out a notification to 72 consultees, comprising:
39 Aviation “National Organisations” (CAA National Air Traffic Management Advisory Committee (NATMAC2) list);
12 Local Aerodromes/Aviation Consultees; 5 Members of Parliament (MP); 11 Council Wards; and 5 Local/National Environmental Organisations.
Of the above, three emails were returned as undelivered. Therefore, the total number of consultees that received the consultation email was 69.
Further detail on the categories of consultee organisations is provided in Section 3.2 of this report.
2.4 Confidentiality
The CAA Safety and Airspace Regulation Group (SARG) requires that all consultation material, including copies of responses from consultees and others, is included in any formal submission to the CAA of an Airspace Change Proposal.
1 ATSOCAS are provided by a variety of air traffic units and used by a wide variety of users from General Aviation to commercial flights and military aircraft. 2 It should be noted that NATMAC comprises a total of 39 organisations, represented by 45 individuals. The consultation document was circulated to each individual. However, this analysis reflects the views of the organisations as a whole and not of the individuals representing them. In some cases it was found that representation had changed from the list provided by the CAA.
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DONG Energy undertakes that, apart from the necessary submission of material to the CAA and essential use by Osprey for analytical purposes in developing this report and subsequent Airspace Change Proposal material, DONG Energy will not disclose personal details or content of responses or submissions to any third parties. Osprey and DONG Energy consultants are signatories to confidentiality agreements in this respect.
2.5 Document structure
This document contains eight main sections and three Annexes, outlined below for convenience:
Section 1 provides a glossary; Section 2, this section, introduces the document; Section 3 details the consultation statistics; Section 4 provides an overview of the responses and support ratio; Section 5 highlights the post-consultation actions; and Section 6 provides a list of references.
There are three Annexes:
Annex A1 details the background to this consultation and the consultation methodology;
Annex A2 lists the consultees; and Annex A3 highlights the key issues arising from the consultation responses.
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3 Consultation Statistics
The Walney TMZ consultation invitations were circulated by email to a total of 72 stakeholder consultee organisations or individuals, of which three were returned as undeliverable. A total of ten responses to this consultation were received.
3.1 Introduction
This section describes the categories of consultee organisations and individuals that were consulted and gives a breakdown of the responses received to date.
3.2 Consultee Organisations
The Walney TMZ consultation invitations were circulated to a total of 72 stakeholder consultee organisations or individuals detailed in Annex A2.
As stated in Section 2.3, three consultation emails was returned as undelivered, making the total number of consultees equal to 69.
The consultation document was distributed via a dedicated link on the DONG Energy website3 and by email to all consultees.
Consultees broadly fall into two categories:
Aviation consultees; and Non-aviation consultees.
Aviation consultees included aviation parties such as MOD, airlines, aircraft operators, adjacent aerodromes, all local airspace users and the national bodies representing all UK aviation interests who may be affected by the regulatory requirements within the TMZ. National bodies such as LAA, BALPA, AOA etc. are represented through the auspices of the NATMAC, sponsored by the CAA. A number of military organisations are also members of the NATMAC.
Non-aviation stakeholders for consultation included environmental and heritage organisations, local planning authorities and the general public. The consultee groups that received the consultation email are detailed in Figure 1 below.
3 http://www.walneyextension.co.uk/en/application-for-consents/consultation-for-transponder-mandatory-zone.
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Figure 1 Distribution of Consultees
3.3 Responses
A total of ten responses (14.5 % of consultees) to this consultation were received. A breakdown of these is provided in Table 1 below.
Consultee Groups Number Consulted4
Responses %
1 NATMAC (Civil) 34 5 14.71
2 NATMAC (Military) 5 1 20.00
3 Local Aerodromes/Aviation Consultees 12 4 33.33
4 MPs 5 0 0
5 Council Wards & Local Authorities 9 0 0
6 National Bodies/Environmental Organisations 5 0 0
7 Individuals N/A 0 N/A
Totals 69 10 14.5 %
Table 1 Responses from Consultees
4 Includes only consultees who received the consultation email.
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Figure 2 Responses from Listed Consultees
It should be noted that “NATMAC (Civil)” and “NATMAC (Military)” comprise those organisations who are members of the CAA’s NATMAC. The NATMAC consultee list includes some CAA Departments who, for reasons of CAA impartiality, do not respond to consultations.
3.4 Meetings with Major Stakeholders
Prior to the commencement of the consultation period, a number of meetings were held with some of the major stakeholders. Although most of these organisations had been contacted during the initial requirements capture phase, the purpose of these meetings was to present the detail that would be incorporated into the Consultation Document to ensure there were no surprises for stakeholders when it came to formal comment.
Details of the pre-consultation meetings that were organised with the major stakeholders are given in Table 2 below.
Stakeholder Meeting Date Notes
BAE Barrow/Walney Island 10th July 2014 Submitted a letter response
Cumbria Airspace Users Forum
24th September 2014 Meeting minutes available
Bond Helicopters 15th August 2014
Table 2 Pre-Consultation Stakeholder Meetings
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4 Analysis of Responses
Of the ten responses received; two consultees supported the proposal; six consultees provided a neutral response, whereby the consultee did not object or provided no comments on the proposal and one consultee objected to the proposal. One consultee raised other comments relating to the presence of the Walney Extension Offshore Wind Farm and not to the development of the Walney TMZ.
4.1 Introduction
This section provides details on the number of responses received from the various organisations and individuals that were consulted. It also explores the support ratio of consultee responses received to give a general indication on the stakeholder acceptance of this proposal.
4.2 Response Support Ratio
As seen in Figure 3, of the ten responses received from the consultee organisations:
Two consultees (20 %) supported the proposal to establish a TMZ over the Morecambe Bay Offshore Wind Farms;
Six consultees (60 %) provided a neutral response, whereby the consultee did not object or provided no comments on the proposal;
One consultee (10 %) objected to the proposal; and One consultee (10 %) raised other comments relating to the presence of the
Walney Extension Offshore Wind Farm and not to the development of the Walney TMZ. Such comments have therefore not been included in the analysis.
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Figure 3 Support Ratio from Listed Consultees
4.3 Key Issues arising from Consultee Responses
The consultation process constitutes the fourth stage of the CAA’s seven-stage ACP (as defined in CAP 725 [Reference 1]). During Stage 1, a requirements capture workshop was organised at BAE Systems Warton. The purpose of this meeting was to undertake a detailed analysis of current operations in the area of the Walney Wind Farms and the challenges those operations face. The workshop further identified current issues and discussed potential airspace constructs that would meet those challenges. Stakeholder identification and management were also discussed.
This workshop was followed by a Framework Briefing with the CAA (Stage 3 of the ACP) to outline the proposed airspace change. Also, as stated in Section 3.4 of this document, prior to the commencement of the consultation period, a number of meetings were held with some of the major stakeholders. The purpose of these meetings was to present the detail that would be incorporated into the Consultation Document to ensure there were no surprises for stakeholders when it came to formal comment.
Consequently, by the time the consultation stage is reached there should have been few areas of contention, highlighted by the major stakeholders that had not previously been raised and addressed. The Consultation Document itself incorporated all the preliminary feedback received from the major aviation stakeholders.
The response analysis process identified just a single issue of concern. This is detailed in Annex A3, together with DONG Energy’s and Warton’s consideration of this concern.
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4.4 Objection
4.4.1 British Handgliding and Paragliding Association
The British Handgliding and Paragliding Association (BHPA) represents over 90% of some 7,000 hand glider, paraglider, powered hand glider and powered paragliders pilots flying in the UK. In response to the consultation, BHPA said that whilst it is extremely unlikely that any of their powered and unpowered pilots would be affected by the proposal, the BHPA object to the proposal because it fails to follow best practice. BHPA further pointed out that there are a number of aspects to the consultation that cause BHPA concern and would be of significantly higher importance should the same matters occur in a proposal for a TMZ in another location.
BHPA stated that the proposed TMZ is considerably larger than it needs to be and should only cover the turbines that cause an issue. BHPA further cast doubt on whether there is sufficient information within the proposal for consultees to be able to reach a meaningful decision with respect to whether the possible radar solutions have been appropriately assessed. BHPA believe that ANSPs should be getting their radar fixed, with it being paid for by the developer if necessary.
4.5 Isle of Man Airport PSR Concerns
Isle of Man Airport (IoMA) expressed their concerns regarding technical omissions to the consultation document and technical effects on the IoMA Primary Surveillance Radar by offshore wind farms.
The issues raised above relate specifically to the presence of the Walney Extension Offshore Wind Farm and not to the proposed TMZ. Following a positive Secretary of State decision on 7th November, on a ‘consent’ for the Walney Extension Offshore Wind Farm, these issues have therefore not been included in this TMZ consultation analysis.
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5 Post-Consultation Actions
No new or unexpected issues have arisen which would affect DONG Energy’s proposal to introduce a TMZ over the Morecambe Bay Offshore Wind Farms. DONG Energy will submit a formal Airspace Change Proposal to the Airspace Regulation (AR) of the CAA detailing the case for the proposed TMZ.
5.1 Post-Consultation Review
All responses received throughout the consultation period have been subjected to a detailed review and analysis by DONG Energy, in order to identify emerging issues of concern.
5.2 DONG Energy Conclusions
Based on the comments received, DONG Energy has concluded that no new or unexpected issues have arisen which would affect DONG Energy’s proposal to introduce a TMZ over the Morecambe Bay Offshore Wind Farms.
5.3 Next Stages of the ACP
The consultation process constitutes the third stage of the CAA’s overall process laid down in CAP 725 [Reference 1] leading to an Airspace Change Proposal.
DONG Energy will submit a formal Airspace Change Proposal to the Airspace Regulation (AR) of the CAA detailing the case for the proposed TMZ. It is a requirement of the consultation process that DONG Energy will provide the CAA with full details of the consultation (including copies of responses and correspondence) together with all documentation necessary for the promulgation of the proposed TMZ.
Following receipt of the formal Airspace Change Proposal, the CAA then requires a 16-week period to conduct its own internal analysis of the final proposal and consultation results, before arriving at a Regulatory Decision. Should the CAA, without the need for further design optimisation or analysis, accept the Airspace Change Proposal, DONG Energy suggest that the implementation of the TMZ would take place on a single date to coincide with the initial operational date of the Walney Extension Offshore Wind Farm, expected to be in mid-2017.
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6 References
Reference Name Origin
1 CAP 725 CAA Guidance on the Application of the Airspace Change Process
Third Edition (corrected) April 2007
CAA
ISBN 978 0 11790 739 3
2 Code of Practice on Consultation
July 2008
Cabinet Office
URN 08/1097
Table 1 Table of References
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A1 Consultation Background and Methodology
A1.1 Background to the Consultation
DONG Energy wishes to develop an extension to the existing operational Walney Offshore Wind Farms (1 and 2), located northwest of Morecambe Bay in the Irish Sea.
The presence of the Walney Extension turbines would affect BAE Systems Warton (Warton) Aerodrome flying and Air Traffic Service (ATS) operations and potentially those of BAE Systems at Barrow/Walney Island Aerodrome, with the most significant effect being the detection of the Walney Extension wind turbines by the Warton Primary Surveillance Radar (PSR). DONG Energy is working with Warton to identify a mitigation to the effect of the turbines on the PSR which will enable the Walney Extension wind turbines to be built without affecting Warton flying operations. Warton’s preferred solution is to establish a TMZ around the Walney, WoDS, Ormonde and Barrow operational Wind Farms and Walney Extension (collectively referred to as the Morecambe Bay Offshore Wind Farms) up to Flight Level (FL)100, (10,000 ft) to be active during the Warton Lower Airspace Radar Service (LARS) provision times.
DONG Energy, as the sponsor of the proposed airspace change, is required to submit a case to the Civil Aviation Authority (CAA) to justify the change in airspace over the Morecambe Bay Offshore Wind Farms. Also, as part of the CAA’s Airspace Change Process (ACP), it is DONG Energy’s responsibility to consult with all relevant stakeholders who may be directly or indirectly affected by the proposal.
A1.2 Method of Consultation
The Walney TMZ consultation was conducted in accordance with the principles set out in the Cabinet Office Code of Practice on Consultation [Reference 2], as required by the CAA.
A comprehensive Consultation Document was prepared by DONG Energy, with the assistance of Osprey. Full details of the proposed change, including rationale, perceived impacts and the mitigation measures undertaken by DONG Energy, were provided in the Consultation Document.
A link to the Consultation Document was made available on the DONG Energy website5. All consultees were notified by email detailing the consultation and how to access the Consultation Document.
Local aviation stakeholders were engaged at an early stage during the design process. Prior to the preparation of the Consultation Document, meetings were conducted with the following major stakeholders:
5 http://www.walneyextension.co.uk/en/application-for-consents/consultation-for-transponder-mandatory-zone
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Blackpool International Airport (BIA)
BAE Barrow/Walney Island;
Cumbria Airspace Users Forum; and
Bond Helicopters.
The primary purpose of these meetings was to present the detail that will be incorporated into the Consultation Document to ensure there are no surprises for stakeholders when it comes to formal comment.
Full consultation commenced with wide circulation of the electronic Consultation Document to all identified stakeholders on 10th October 2014 on completion of the design process and environmental studies. The consultation process ran until 11th January 2015 - a period of fourteen weeks. This allowed a minimum of twelve weeks required for formal consultation6, recognised the number of Public Holidays during the period and provided scope for any unforeseen delays at the start, or any significant issues that may arise during the process.
Consultees were asked to consider the proposal and submit a response to DONG Energy using a response form on the DONG Energy consultation website or through a dedicated email address ([email protected]).
In order to promote maximum response, three reminder emails were sent to those consultees who had not yet provided a response to date. The first reminder was sent on 20th November 2014 (more than one month before the end of the consultation period) and a second reminder email on 22nd December 2014, to those consultees who had not yet responded to date. A third email reminder was sent to only the aviation stakeholders (NATMAC) who had not yet responded to date.
6 The Cabinet Office Code of Practice on Consultation [Reference 2] and the CAA requirements specify a minimum period of 12 weeks for consultation.
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A2 Stakeholder / Consultee List
A2.1 Aviation Consultees: Aerodromes / Local Aviation Consultees
Consultee Also known As
Blackpool International Airport EGNH
Bond Offshore Helicopters
Caernarfon Aerodrome Bangor
Chester Hawarden EGNR
City (Barton) Heliport Manchester
EGCB
Ince West Lancashire Microlight
Isle of Man Airport EGNS
Liverpool John Lennon Airport EGGP
Lleweni Parc Airfield Denbigh Gliding
RAF Woodvale EGOW
Barrow/Walney Island EGNL
Lakes Gliding Club
A2.2 Aviation Consultees: National Organisations (NATMAC)
Consultee Also known As
Aircraft Owners and Pilots Association AOPA UK
Airport Operators Association AOA
Association of Remotely Piloted Aircraft Systems ARPAS
Aviation Division Navy Command Headquarters NCHQ
Aviation Environment Federation AEF
BAESystems Warton BAES
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British Air Transport Association BATA
British Airline Pilots’ Association BALPA
British Airways BA
British Association of Balloon Operators BABO
British Balloon and Airship Club BBAC
British Business and General Aviation Association BBGA
British Gliding Association BGA
British Hang Gliding and Paragliding Association BHPA
British Helicopter Association BHA
British Microlight Aircraft Association BMAA
British Model Flying Association BMFA
British Parachute Association BPA
Civil Aviation Authority CAA SRG
Defence Airspace and Air Traffic Management (incl. the Military User Advisory Consultative Team)
DAATM (MUACT)
Euro UAV Systems Centre Ltd
European Low Fares Airline Association ELFAA
General Aviation Safety Council GASCo
Guild of Air Pilots and Air Navigators GAPAN
Guild of Air Traffic Control Officers GATCO
Headquarters Director Army Aviation HQ DAAvn
Heavy Airlines
Helicopter Club of Great Britain HCGB
Light Aircraft Association LAA
Light Airlines
Low Fares Airlines
Military Aviation Authority MAA
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Ministry of Defence MOD
MOD Flight Test Regulator
NATS (NSL) NSL
NATS En-Route Ltd NERL
PPL/IR Europe PPL/IR
RAF Safeguarding Team RAF ST
The British Business and General Aviation Association BBGA
UK Airprox Board UKAB
UK Flight Safety Committee UKFSC
3 AF-UK/A3
A2.3 Non-Aviation Consultees: National Bodies
Consultee
National Trust for England
English Natural Heritage
Friends of the Earth
Campaign to Protect Rural England
Natural England
A2.4 Non-Aviation Consultees: Regional Council Authorities
Consultee
Barrow-In-Furness Council
Copeland Borough Council
Fleetwood Town Council
Lancaster City Council
South Lakeland Council
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A2.5 Non-Aviation Consultees: Regional Council Authorities
Borough of Barrow-In-Furness
Consultee
Askam and Ireleth Parish Council
Walney North Ward
Walney South Ward
Roosecote Ward
Copeland Borough Council
Consultee
Haverigg Ward
Millom
Fleetwood Town Council
Consultee
Pharos Parish
Warren Parish
Rossall Parish
Lancaster City Council
Consultee
Bolton-Le-Sands
Carnforth Ward
Harbour Ward
Heysham North
Heysham Central
Heysham South
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South Lakeland District Council
Consultee
Arnside and Beetham
Grange North
Grange South
Ulverston East
Ulverston South
A2.6 Information Organisations: Members of Parliament
UK Parliament
Consultee Constituency
John Woodcock MP Barrow and Furness
Jamie Reed MP Copeland
Eric Ollerenshaw MP Lancaster and Fleetwood
David Morris MP Morecambe and Lunesdale
Tim Farron MP Westmorland and Lonsdale
A2.7 Information Organisations: Civil Aviation Authority
Consultee Also known As
Safety and Airspace Regulation Group SARG
Safety and Airspace Regulation Group Head of Aerodrome & Air Traffic Standards Division
SARG AAA Manager Aerodromes
Safety and Airspace Regulation Group Flight Ops Division
SARG Flight Ops Division
Safety and Airspace Regulation Head of Airspace Regulation
SARG AAA Manager Airspace Regulation
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A3 Key Issues arising from the Consultation
Issue Specimen Comment DONG Energy/Warton
Comment
1 Impact on
handgliders and
paragliders
The matters of concern are:
1. Page 14, “The existing operational
Walney 1 and 2, Ormonde and Barrow
Wind Farms do not affect the Warton PSR,
as the wind turbines are smaller than
those planned for the extension. However,
whilst the existing operational turbines do
not affect the Warton PSR, from an
airspace user’s visual perspective DONG
Energy and Warton consider that if
mitigation involves a change to local
airspace arrangements, then it is simpler
to encompass all wind turbines in the
immediate area. It would be difficult for a
pilot to make a visual distinction between
the existing Morecambe Bay Offshore
Wind Farm turbines and those of the
planned Walney Extension.”
This means that because producers of the
proposal doubt the abilities of pilots to
navigate (with no evidence to support this
assertion) the TMZ is considerably larger
than it needs to be. Following the airspace
principles from the CAA the TMZ should
only cover those turbines that cause an
issue.
2. Paragraph 6.3.1, “It is not possible
to remove only the radar returns from the
wind turbines without also removing
‘wanted’ radar returns from aircraft. This
is why PSR Blanking in isolation is not
considered a viable mitigation for the
Walney Extension.”
The following links would appear to show
The concern regarding the size of
the consulted TMZ is noted but
not supported by evidence from
individuals within the project
who have flown over the
Morecambe Bay Offshore Wind
Farms during various VMC. On
many occasions of varying
visibility, natural lighting and
direction of travel the extent and
boundaries of the subject Wind
Farms can be indistinguishable.
Your concern regarding technical
solutions to mitigate the effects
of wind turbine generated
‘clutter’ on a PSR is
acknowledged, it is recognised
that there are a number of
‘radar’ solutions being
developed, and have been
demonstrated, by various
manufacturers. These solutions
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this to be inaccurate:
http://helihub.com/2014/10/20/new-
airport-radar-to-mitigate-impact-of-wind-
turbines/
http://www.aveillant.com/news/problem-
radar-isnt-wind-farms-its-radar/
3. There is insufficient information
within the proposal for consultees to be
able to reach a meaningful decision with
respect to whether the possible radar
solutions have been appropriately
assessed. It could be that the TMZ is the
cheapest option so radar remediation was
written up as technically too difficult in
order to maximise profit. We believe that
ANSPs should be getting their radar fixed,
with it being paid for by the developer if
necessary.
are being closely scrutinized as
part of the UK Government’s
commitment to offshore
renewable energy recovery and
its renewable targets. Due to the
large number of wind turbines
planned for the Walney Offshore
Extension Wind Farm, and other
turbines existing within its close
proximity, simple radar
modifications to provide
mitigation are not possible with
the existing technology.
It is BAES Warton’s view that
PSR solutions are not yet fully
developed. Furthermore, these
PSR solutions to not yet fully
address system and aerodrome
environment intergation and
would currently occasion
unacceptable technical risk to
BAES and Warton’s operations.
This is not to say that an
acceptable technical mitigation,
meeting CAA and MoD approval,
will not be available, and
acceptable to Warton, in the
future which would thence
demand the subsequent removal
of the TMZ.