Manston Airport Safeguarding Assessment · Author Osprey CSL Reviewer Osprey CSL Approver Osprey CSL . ... established and assessed in relation to the proposed communications masts

FOR PLANNING PURPOSES

Date: 13th April 2016

Revision: Version 2

Osprey Ref: 70990 002

This document is of UK origin and has been prepared by Osprey Consulting Services Limited (Osprey) and, subject to any existing rights of third parties, Osprey is the owner of the copyright therein. The document is furnished in confidence under existing laws, regulations and agreements covering the release of data. This document contains proprietary information of Osprey and the contents or any part thereof shall not be copied or disclosed to any third party without Osprey’s prior written consent.

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Manston Airport Safeguarding Assessment

Effect of Proposed Communication Masts to Operations conducted at a reopened Manston Airport


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Document Details

Reference Description

Document Title Manston Airport Safeguarding Assessment

Effect of Proposed Communication Masts to Operations conducted at a reopened Manston Airport

Document Ref 70990 002

Issue Version 2

Date 13th April 2016

Client Name RiverOak Investment Corp

Classification For Planning Purposes

Approval Level Authority

Author Osprey CSL

Reviewer Osprey CSL

Approver Osprey CSL


Manston Airport Safeguarding Assessment | Executive Summary

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Executive Summary

Riveroak Investment Corp (RiverOak) is investing in the future use of Manston Airport (formally Kent International Airport) and has commissioned Osprey Consulting Services Limited (Osprey) to assess what the potential impact of two proposed mast developments would be if the airport were licensed and regulated in accordance with Civil Aviation Authority (CAA) and European Aviation Safety Agency (EASA) standards.

As its purpose is to inform relevant Planning Authorities, this review focuses on the masts as physical obstructions to aviation. It does not consider broader issues such as electromagnetic interference, lighting or impact on the wider aviation communities; these may also need to be taken into account when considering these proposals.

As part of this assessment, the Obstacle Limitation Surfaces (OLS) for the airport were established and assessed in relation to the proposed communications masts. It was found that the two masts would penetrate the Manston Airport Inner Horizontal Surface (IHS) (Richborough Power Station Mast (Vigilant)) and the Manston Airport Conical Surface (Kings End Farm (NLN) Mast). The extent of the breach created by each mast is significant; Osprey assess that if Manston Airport were currently operational, safety concerns associated with such a severe breach so close to the airport, would cause the airport operator to object to the developments on the grounds of CAA Airport Safeguarding Regulations.

Turning to arrival and departure procedures, the minimum vectoring altitude in the vicinity of the communication masts would have to be increased to 2,100 feet, (an increase of 600 feet)). This is to ensure the required vertical clearance between aircraft in receipt of an Instrument Flight Rules (IFR) service from Air Traffic Control, and the top of the mast structures, is maintained. This increase may also impact the design of any new Instrument Flight Procedures (IFPs) for the airport and may affect any decision on suitable holding heights. It would also have to be taken into account by controllers when vectoring aircraft in the vicinity of the airport. Whilst such changes would impact IFR operations at Manston Airport, Osprey considered that such an impact could be managed successfully.

For aircraft operating under Visual Flight Rules (VFR), the proposed communication masts represent a much greater hazard. Aircraft operating in Manston’s southerly visual circuit would be confronted by the masts at circuit height as they turned downwind. Aircraft are legally obliged to avoid such obstructions by 500 ft laterally or vertically but they can be difficult to see from the air especially in marginal weather conditions and particularly whilst undertaking busy and critical stages of flight, such as an approach to land or immediately after departure. To partially mitigate this risk, changes to the routing or altitude of the visual circuit could be made but these would themselves introduce new, and potentially more severe, risks. Use of the northerly circuit would reduce the risk to visual circuit operations but would concentrate the noise footprint and other environmental effects over a populated area used for tourism and recreation. Even if such measures were applied, the risk to VFR operations to the south of the airport cannot be managed, despite the application of mitigation measures (which may change but not address the hazards). Osprey assess that if Manston Airport were currently operational, its operators would object to the mast developments on the grounds of their threat to the safety of aircraft operating VFR to the south of the airport, particularly in the visual circuit.


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The purpose of an Air Traffic Zone (ATZ) at Manston Airport would be to provide protection to aircraft departing, arriving or flying in the vicinity of the airport by ensuring that any aircraft in the immediate vicinity is required to contact ATC. It is not intended to ensure terrain and obstacle clearance to either IFR or VFR operations (including the visual circuit); these are covered under other regulations. Although the process outlined in CAP 724 takes into account a range of factors when considering whether an ATZ should be granted, it would not take into account the Vigilant and NLN mast developments. However, while Osprey assess that, in theory, the proposed communication masts would have little impact on Manston Airport’s application for an ATZ, in practice they would have such an operational impact on IFR procedures and such a significant operational and safety impact on VFR procedures, that the case for establishment of an ATZ would be undermined.

In summary, the proposal to develop communication masts to the south of Manston Airport would significantly infringe the CAAs OLS criteria, which are specifically established to ensure safe operations in the vicinity of an airport. The severity of this infringement, which cannot be fully mitigated, could undermine Manston Airports case for a CAA License and EASA approval. This, in turn, would have significant commercial implications as operators may not wish (or be able) to operate from an unlicensed or non-EASA compliant airport. While Osprey consider that IFR procedures could be modified to accommodate the masts and Manston Airports case for an ATZ is likely to be unaffected by them, the masts would represent a considerable flight safety hazard to aircraft operating VFR to the south of the Airport and particularly in its southerly visual circuit. Mitigation measures would either introduce new risks or significantly increase noise over the main built up areas of Margate, Broadstairs, Ramsgate, and Herne Bay; even then, the safety risk to VFR operations to the south of the airport would remain and could not be mitigated.

Osprey therefore conclude that, if Manston Airport were currently operational, its Operators would object to the proposed mast developments on the following grounds:

- The severity of their penetration of the Airports OLS.

- The flight safety risk they would represent to aircraft operating VFR to the south of the airport, particularly those operating in its southerly visual circuit.


Manston Airport Safeguarding Assessment | Table of Contents

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Table of Contents

1 Introduction ................................................................................................................................. 1

1.1 Overview ........................................................................................................................................................ 1 1.2 Details of the Proposed Communication Masts ............................................................................. 1 1.3 Background ................................................................................................................................................... 2 1.4 Scope ............................................................................................................................................................... 2 1.5 Document Structure .................................................................................................................................. 3

2 The Communication Masts ...................................................................................................... 5

2.1 Overview ........................................................................................................................................................ 5 2.2 Vigilant Mast................................................................................................................................................. 6 2.3 Kings Head Farm Mast ............................................................................................................................. 6

3 Control of Obstacles in the Vicinity of Aerodromes ....................................................... 7

3.1 Overview ........................................................................................................................................................ 7 3.1 OLS: Overview ............................................................................................................................................. 7 3.2 Obstacle Limitation Surfaces ................................................................................................................. 8 3.3 Restriction and Removal of Obstacles ............................................................................................... 9 3.4 Aerodrome Safeguarding – Obligations ............................................................................................ 9 3.5 Marking and Lighting of Obstacles – Obligations .......................................................................... 9

4 Manston Airport Safeguarding ............................................................................................ 11

4.1 Overview ..................................................................................................................................................... 11 4.2 Obstacle Limitation Surfaces at Manston Airport...................................................................... 11 4.3 Inner Horizontal Surface (IHS) .......................................................................................................... 12 4.4 Conical Surface ......................................................................................................................................... 12 4.5 Conclusions ................................................................................................................................................ 14

5 Manston Instrument Approach Procedures ................................................................... 15

5.1 Runways and Airspace .......................................................................................................................... 15 5.2 Air Traffic Control (ATC) Radar Operations at Manston ........................................................ 16 5.3 Instrument Flight Rule Procedures ................................................................................................. 17 5.4 Radar Vectored Approaches ............................................................................................................... 19 5.5 Application of the RVA at Manston Airport .................................................................................. 20 5.6 Communication Transmitters Fresnel Zone ................................................................................ 20 5.7 Terrain/Obstacle Clearance Criteria ............................................................................................... 20 5.8 Conclusions ................................................................................................................................................ 22

6 Manston Visual Circuit Procedures ................................................................................... 24

6.1 Overview ..................................................................................................................................................... 24



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6.2 Manston Visual Circuit Operations .................................................................................................. 24 6.3 Impact Created by the Communication Masts on Visual Circuit Operations ................. 25 6.4 Aviation Objections ................................................................................................................................ 26 6.5 Visual Circling Operations ................................................................................................................... 26 6.6 Search and Rescue Operations .......................................................................................................... 27 6.7 Conclusions ................................................................................................................................................ 27

7 Manston Airport - Airspace .................................................................................................. 29

7.1 Overview ..................................................................................................................................................... 29 7.2 Purpose of an ATZ ................................................................................................................................... 29 7.3 Application Process ................................................................................................................................ 30 7.4 Conclusions ................................................................................................................................................ 31

8 Conclusions ................................................................................................................................. 32

8.1 Overview ..................................................................................................................................................... 32 8.2 OLS ................................................................................................................................................................ 32 8.3 Instrument Procedures/Radar Vectoring Area .......................................................................... 32 8.4 Visual Circuit Operations ..................................................................................................................... 32 8.5 ATZ ................................................................................................................................................................ 33

9 References .................................................................................................................................. 34

A1 CAA Approved Procedure Designer Report .................................................................... 36

A1.1 Overview ..................................................................................................................................................... 36 A1.2 Instrument Departure Procedures ................................................................................................... 36 A1.3 Aircraft Holding Pattern ....................................................................................................................... 37 A1.4 Visual Manoeuvring Procedures following an Instrument Approach ............................... 37 A1.5 Aircraft Flying Visual Circuits ............................................................................................................. 37 A1.6 Other Airfield Examples ........................................................................................................................ 38 A1.7 General Comments on OLS................................................................................................................... 38 A1.8 Summary ..................................................................................................................................................... 38

A2 Osprey Brief Résumés............................................................................................................. 39

A2.1 Overview ..................................................................................................................................................... 39

Table of Figures

Figure 1 Location of the Vigilant Richborough Mast and the NLN Kings Head Farm Mast site centre. .................................................................................................................................................................................... 5 Figure 2 Vigilant Richborough Mast Location ...................................................................................................... 6 Figure 3 Illustration of the IHS and Conical Surfaces ........................................................................................ 8 Figure 4 Location of the Masts within Lateral Boundaries of Affected Manston OLS (not to scale) ............................................................................................................................................................................................... 13 Figure 5 Illustration of the breach of the Manston OLS created by the two masts. ........................... 14 Figure 6 Existing tall structure to the South of Manston Airport .............................................................. 16 Figure 7 Manston IFP and the Location of the two Proposed Masts ........................................................ 18



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Figure 8 Manston RVA as published when Manston was active ................................................................ 19 Figure 9 Manston RVA with inclusion of the highest altitude of the masts (not to scale) .............. 22

Table of Tables

Table 1 Calculation on Assessing Impact to the Manston RVA if the Masts are constructed. ........ 21 Table 2 Table of References ...................................................................................................................................... 35


Manston Airport Safeguarding Assessment | Introduction

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1 Introduction

This section introduces the background, methodology and scope of the assessment.

1.1 Overview

Riveroak Investment Corp (RiverOak) is committed to the reopening of Manston Airport (formerly Kent International Airport) and are in early discussions with the Planning Inspectorate about submitting an application for a Development Consent Order (DCO) for what would be a Nationally Significant Infrastructure Project (NISP).

RiverOak has commissioned Osprey Consulting Services Limited (Osprey) to undertake an assessment of the potential for two proposed communication masts to influence operations at Manston Airport were it reopened and licensed in accordance with Civil Aviation Authority (CAA) and European Aviation Safety Agency (EASA) Regulations.

The purpose of this review is to inform relevant Planning Authorities on the potential aviation impact of both developments; as such it focuses on the masts as physical obstructions to aviation. It does not consider broader issues such as electromagnetic interference, lighting or impact on the wider aviation communities; these may also need to be taken into account.

CAA Civil Aviation Publication (CAP) 168 Licensing of Aerodromes [Reference 1] sets out the standards required at UK licensed aerodromes relating to management systems, operational procedures, physical characteristics, assessment and treatment of obstacles, visual aids, rescue and fire-fighting services and medical services. Other relevant existing legislation regarding land-based obstacles to air navigation includes the following:

Obstacles close to licensed aerodromes: Section 47, Civil Aviation Act 1982; Obstacles close to government aerodromes: Town and Country Act,

(Government permitted development) Order 2000; and Lighting of en-route obstacles: Article 219, Air Navigation Order (CAP393).

1.2 Details of the Proposed Communication Masts

The Vigilant Global Ltd (Vigilant) proposal is for a single steel lattice mast 322 metres (m) in height (324 m Above Ordnance Datum (AOD)) together with nine anchor points, installation of telecommunications and associated equipment, site compound, secure fencing, single storey equipment structure, and associated works at the former Richborough Power Station, Ramsgate Road, Sandwich, CT13 9NL. The Dover District Council (DDC) planning application reference number is 16/00044.

New Line Networks (NLN) is a separate proposal for a mast at Kings End Farm close to the proposed Vigilant mast. The NLN proposal is a 305 m ‘slim-line’ mast between



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the settlements of Ash, Sandwich and Minster and within the DDC border. NLN is expected to submit the planning application in the spring of 2016. If approved, construction is scheduled to start during 2016 with completion during the first half of 2017.

1.3 Background

The effects of obstacles on aviation interests have been widely publicised; the primary concern is one of safety with operational effectiveness and efficiency as additional considerations. Such obstructions can have a physical and/or technical impact on an airport. For example, buildings and the erection of new structures can present a physical obstruction at or close to an aerodrome which despite their size, can be difficult to see from the air in certain weather conditions. Equally, airport runways, procedures and Communications and Navigation Systems (CNS) also require protection. The scale of any impact, and measures that can be employed to mitigate it, is often dependent on the size of the airport, the nature of the control service it provides and the type of procedures used at the airport.

For example an aerodrome/airport can be either:

Licensed – where the CAA must be satisfied that the applicant for, or holder of an aerodrome license has control over or access to the operational areas of the aerodrome in order for him to meet his obligations under the Air Navigation Order.

Or

Unlicensed – where the relevant CAP 793 Safe Operating Practices at Unlicensed Aerodromes [Reference 2] contents are not mandatory, nor do they purport to be exhaustive. However, they do provide what can be considered as sound practice that has been developed in consultation with industry representative bodies.

Equally, they can elect to be compliant with European Aviation Regulations or purely national (CAA) ones.

Due to the commercial and international nature of its operation, Manston would be a Licensed Airport that is compliant with European (EASA) regulations; this, in turn, places considerable responsibility on the Airport to manage and assure a safe operating environment.

1.4 Scope

This Safeguarding Assessment considers the potential impacts of the proposed communication masts once fully complete and excludes any safety or operational issues relating to their construction. However, CAP 738 Safeguarding of Aerodromes [Reference 4] provides the following information for aviation stakeholders with regard to the use of cranes within their safeguarded areas:

“Should a crane be required on or in the vicinity of an aerodrome, the attention of the crane operator should be brought to the British Standard Institute Code of Practice for the safe use of Cranes, BS 7121, Part 1. In particular, paragraph 9.3.3 sys that the appointed person should consult the aerodrome/airfield manager for permission to



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work if a crane is to be used within 6 km of the aerodrome/airfield and its height exceeds 10 m or that of the surrounding structures or trees”.

Previous Instrument Flight Procedures (IFPs) established at Manston were located to allow aircraft to be positioned accurately on the extended centreline of the runway. Any new IFPs established at Manston will need to be designed by a CAA approved and accredited procedure designer. A review has been completed of the previously published flight procedures and the influence the construction of the Vigilant Mast may have. It is expected that, due to its proximity to the Vigilant Mast, the influence of the New Line Networks Mast proposal upon IFPs will be similar. Given the desire to reopen for commercial /freight flights, a consideration of future likely procedures was also taken. The reviewer is a current commercial pilot, CAA approved Instrument Flight Procedure Designer, and flying examiner/instructor. The report is contained within Annex 9A1 to this document.

1.5 Document Structure

This document utilises the following structure:

Section 1 (this section) introduces the report; Section 2 provides further details of the proposed communication masts; Section 3 provides an overview of the control of obstacles within the vicinity

of aerodromes; Section 4 identifies the lateral and vertical extent of the relevant protected

surfaces at Manston (should it be licensed to operate) near the proposed communication masts and provides an analysis of the two masts in relation to the airport’s Obstacle Limitation Surfaces (OLS);

Section 5 presents an overview of previous instrument operations conducted at Manston, its previous instrument flight procedures and any constraints the communication masts may create on any new procedures that might be developed;

Section 6 considers the potential of both developments sites, to affect visual circuit operations which were previously flown to the south of the aerodrome and the potential of the communication masts to affect Search and Rescue (SAR) operations if SAR helicopters are operated/based at the aerodrome;

Section 7 considers the impact the two communication masts may create to Manston’s prospects of reinstating the Aerodrome Traffic Zone (ATZ) and the anticipated CAA airspace change requirement;

Section 8 includes the conclusions taken from the assessment; and Section 9 provides a list of references.

There are two Annexes

Annex 1 provides the report completed by a CAA approved Instrument Flight Procedure Designer; and

Annex 2 delivers background information on Osprey personnel who have compiled this assessment.



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Manston Airport Safeguarding Assessment | The Communication Masts

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2 The Communication Masts

This section provides details of the two communication masts, which are proposed adjacent to the location of Manston Airport.

2.1 Overview

Figure 1 below provides an illustration of the location of the communication masts, the 10 nautical mil (NM) circle is centred on the Manston Airfield Reference Point1 (ARP).

The map above shows estimated location data which may be subject to error and is provided for reference only. This map has been produced by Osprey Consulting Services Ltd using the OS OpenData 1:250000 2009 Scale Raster. Contains Ordnance Survey Data © Crown Copyright and database right 2013.’

Figure 1 Location of the Vigilant Richborough Mast and the NLN Kings Head Farm Mast site centre.

1 Airfield Reference Point is the centre point of an airfield located at the geometric centre of all useable runways.


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2.2 Vigilant Mast

Vigilant have submitted a planning application for the erection and operation of a guyed steel lattice communications mast with nine support stays and anchor points, site compound, secure fencing, single storey equipment structure, solar panels and associated works on approximately 0.5 hectare of land at Richborough, Kent, midway between Ramsgate and Sandwich at location N51 18’ 38.31”, E1 20’ 19.32”. The mast would be up to 322 m above ground level (agl) and be approximately 3.57 kilometres (km) (1.92 NM)) on a bearing of 188° from the Manston Airport ARP. The approximate land elevation at the mast site is 1 m.

Reproduced from Ordnance Survey digital map data © Crown Copyright 2015

Figure 2 Vigilant Richborough Mast Location

2.3 Kings Head Farm Mast

The NLN Kings Head Farm communications mast will provide communication links between the UK and the rest of Europe. The mast will have the ability to transmit information for financial networks and NLN state that the mast will improve the effectiveness of local community radio, satellite TV, mobile operators and emergency services. An antenna positioned on top of the mast will transmit a microwave signal in a focused, narrow beam directly to a structure on the European mainland. In light of the claims regarding improved radio, TV and phone coverage it is not clear what additional antenna will be sited on the mast. The centre of the development site is located at N51 18’ 19.57”, E1 19’ 30.61”. The mast would be at a height2 of 305 m and be approximately 4.33 km (2.3 NM) on a bearing of 199° from the Manston ARP.

2 It is assumed this measurement is the height of the mast agl. The elevation above mean sea level at the location of the NLN mast is approximately 2 m.


Manston Airport Safeguarding Assessment | Control of Obstacles in the Vicinity of Aerodromes

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3 Control of Obstacles in the Vicinity of Aerodromes

Regulatory guidance issued by the UK CAA states that certain areas of local airspace must be defined to assess the significance of existing or proposed obstacles within the vicinity of an aerodrome; these are Obstacle Limitation Surfaces (OLS).

Note; the calculations in this assessment are based on standard dimensions of the applicable safeguarding areas around an aerodrome, and on estimated ground heights within the development sites.

3.1 Overview

Obstacles inside and outside an aerodrome’s boundary can affect operations, including take-off, landing, and arrival or departure procedures; they can also interfere with the signals from some navigation aids. The CAA issues regulatory guidance on how aerodromes should manage operations in relation to obstacles. The licensing of an aerodrome and the retention of that license depends on the extent to which these areas are free from current or new obstacles. The guidance is contained within:

CAP 168 Licensing of Aerodromes [Reference 1]; CAP 232 Aerodrome Survey Requirements [Reference 5]; and CAP 738 Safeguarding of Aerodromes [Reference 4].

The regulatory guidance states that certain areas of local airspace must be regarded as integral parts of the aerodrome environment, these areas are defined to allow the significance of existing or proposed obstacles within the vicinity of an aerodrome to be assessed. These areas are laid down as OLS, which comprise a series of 3-dimensional slopes and horizontal planes which extend out from the aerodrome. The OLS are determined according to the classification of the aerodrome and its runway length.

3.1 OLS: Overview

In this report, Osprey has considered only those surfaces potentially affected by the proposed communication masts.

Where a surface is subject to infringement (by an existing or a proposed obstacle), CAP 168 [Reference 1] states that any required safety measures will have regard to:

The nature of the obstacle and its location relative to surface origin, to the extended centreline of the runway or normal approach and departure paths and to existing obstacles;

The amount by which the surface is infringed; The gradient presented by the obstacle to the surface origin; Type of air traffic at the aerodrome; and Instrument Approach Procedures (IAP) published for the aerodrome.



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Suggested safety measures include but are not limited to:

Promulgation in the UK IAIP [Reference 3] of appropriate information; Marking and/or lighting of the obstacle; Variation of the runway distances declared as available; Limitation of the use of the runway to visual approaches only; and Restrictions on type of traffic using the runway.

Note: not all of the above may be appropriate for a given aerodrome.

The degree of freedom from obstacles must be determined by survey in accordance with CAP 232 [Reference 5].

3.2 Obstacle Limitation Surfaces

3.2.1 Inner Horizontal Surface (IHS)

The IHS is a horizontal plane that extends out from the airport and its vicinity. Its height above the elevation of the lowest runway threshold and the distance to which it extends depends on the scale and nature of the airport operations. To ensure safe visual manoeuvring of aircraft, airports are required to consider developments which penetrate through this surface. They are also required to consider the removal or marking of existing obstacles.

3.2.2 Conical Surface

A conical surface is a surface sloping upwards and outwards from the periphery of the inner horizontal surface. It represents the level above which consideration needs to be given to the control of new obstructions and the removal or marking of existing obstructions to ensure safe visual manoeuvring in the vicinity of an aerodrome. A conical surface is established for every aerodrome.

Figure 3 Illustration of the IHS and Conical Surfaces

Figure 3 above is provided for illustrative purposes only. As will be outlined below, the size and gradient of the various OLS surfaces is dependent on the nature of the aircraft and operation at each airport.

http://www.google.co.uk/url?sa=i&rct=j&q=&esrc=s&source=images&cd=&cad=rja&uact=8&ved=0ahUKEwiHlvyRs_zLAhUDPhQKHZh-BPoQjRwIBw&url=http://www.austlii.edu.au/au/legis/cth/li/mosp139a320/F2010C00819/2/&bvm=bv.118817766,d.ZWU&psig=AFQjCNGrwQoGYo7O8naoBKgAR5pVV74w9Q&ust=1460114055153684



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3.3 Restriction and Removal of Obstacles

CAP 168 [Reference 1] states:

“New objects, or additions to existing objects, should not extend above an inner horizontal surface, a conical surface or an outer horizontal surface, except, when in the opinion of the CAA, the object would be shielded by an existing immovable object, or it is determined that the object would not adversely affect the safety or significantly affect the regularity of aircraft operations.”

The concept of shielding only applies where there is a substantial and permanent object, or natural terrain feature, that already penetrates the OLS. The CAA may accept (at their discretion) objects of lesser or equal height around this shielding object penetrating the surface; there is no apparent shielding, near Manston, of the two communication masts to minimise any effect to the OLS.

Cap 168 further states that:

“Existing objects above an approach surface, transitional surface, take-off climb surface, inner horizontal surface or conical surface should as far as practicable be removed, except when in the opinion of the CAA the object is shielded by an existing immovable object”

3.4 Aerodrome Safeguarding – Obligations

Aerodrome operators are required to observe the detailed guidance contained in CAP 738 [Reference 4] and in doing so “...take all reasonable steps to ensure that ... the aerodrome and its airspace are safe at all times for use by aircraft”.

Although not presently active, it is envisaged that Manston will become a licensed aerodrome, which will have a set of procedures included in its Aerodrome Manual that enables Manston to fulfil these obligations. The procedures applicable to the potential obstacle limitation infringement are published in CAP 168 [Reference 1]:

Accountability with regards to safeguarding and a system for recording consultations including a method for seeking advice on issues of surface infringement and if officially safeguarded, clearly stated call-in procedures;

Procedures for evaluating potential impact on instrument approach procedures; and

Procedures for promulgating infringement in the UK IAIP where appropriate.

RiverOak are currently conducting a retrospective review of developments within the safeguarded area to ensure continuity in its safeguarding obligations since Kent International Airport closed.

3.5 Marking and Lighting of Obstacles – Obligations

In accordance with CAP 393 Air Navigation: the Order and the Regulations [Reference 6]; Article 219, all objects that extend to a height of 150 m or more above ground elevation are regarded as obstacles and shall be appropriately lit. Objects of a lesser height, which are assessed as being ‘hazards to aviation’, are also treated as obstacles and hence required to be lit. The purpose of lighting such obstacles is to reduce the hazard to aircraft operating at lower altitudes and near the ground.



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The CAA does not allocate responsibility for the lighting of obstacles (near an aerodrome) to either the aerodrome operator or the obstacle owner; however, it may suspend, vary or withdraw an aerodrome license if the lighting requirements are not met.

An object that infringes the OLS at an aerodrome is deemed by the CAA to be an “aerodrome obstacle” and if the object cannot be removed, it must be marked and lit (if the aerodrome is used at night)


Manston Airport Safeguarding Assessment | Manston Airport Safeguarding

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4 Manston Airport Safeguarding

Although not presently operational, details of the airport’s previous commercial operation (runway length, location and operating procedures etc.) have been used in the assessment of OLS at Manston Airport and in accordance with CAP 168 Licensing of Aerodromes.

4.1 Overview

Before closure, Manston operated a single runway which was the tenth longest in the UK, and which was capable of handling some extra-large and heavy aircraft. Commercial operators flew daily passenger services, with further activity from regular Inclusive Tour (IT) charter flights to European destinations and heavy cargo airline operations to destinations worldwide. A large hangar on the airfield supported large aircraft servicing and was utilised on a regular basis.

4.2 Obstacle Limitation Surfaces at Manston Airport

The runway at Manston had a longest Take-Off Distance Available (TODA) of 3,169 m and was orientated at 10/283 (True Bearing 101.24°/281.27°). The Aerodrome ARP was at N51°20’32”, E1°20’46” at the mid-point of Runway 10/28.

A runway reference code is established for each aerodrome in accordance with CAP 168 [Reference 1], and comprises:

A number (between 1 and 4) determined by selecting the higher value of declared TODA or Accelerate-Stop Distance Available (ASDA); and

A letter (ranging from A to F) which corresponds to the wingspan or main outer-wheel span, whichever is the more demanding, of the largest aircraft likely to be operating at the aerodrome.

The Aerodrome Reference Code is used to determine the extent of the lateral, longitudinal and sloping planes of the airspace and ground surfaces surrounding each runway that should be kept free of obstacles; essentially the size and gradient of the various OLS surfaces outlined above.

The Aerodrome Reference Code of Manston would be 4E based on CAP 168:

• As the main runway at Manston was 3,169 m in length, (Take Off Distance Available (TODA) Runway 10 3,169 m) and 61 m wide.

Osprey has considered only those surfaces potentially affected by the proposed developments based on the relative location of the communication masts to Manston and their heights. The sections below detail the affected OLS at Manston as assessed in accordance with CAP 168. The OLS presented are based on a runway to which

3 Runway numbers are determined by their heading. Runway 10/28 is facing approximately a magnetic heading of 100° in one direction, and 280° in the opposite direction.



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instrument approaches 4 were conducted, as was the case for Manston before its closure and is currently planned.

4.3 Inner Horizontal Surface (IHS)

Based on CAP 168 and the Aerodrome Reference Code 4E, Osprey has calculated the characteristics of the surfaces at Manston. Figure 4 below illustrates that as the Manston runway was of 1,800 m or more in length, circles of radius 4000 m (4 km) are described centred on the strip ends of the runway. These circles are joined by common tangents parallel to the runway centreline to form a racetrack pattern. The boundary of this pattern is the boundary of the IHS. The Vigilant Richborough Mast located at approximately 3.57 km from the Manston ARP lies within the lateral boundary of the IHS, which, extends out to 4 km from the runway at a height of 97.1 m, and penetrates the IHS protected surface by 224.9 m.

4.4 Conical Surface

The centre of the NLN Kings Head Farm development site is located approximately 4.3 km from the Manston ARP and falls outside of the lateral boundary of the IHS.

The conical surface extends from the outer edge of the IHS. It slopes upwards with a gradient of 5% until the outer limit reaches 105 m above the IHS for a Code 4 runway such as that at Manston. Thus, the highest extent of the conical surface is 150 m above the elevation of the lowest runway threshold and the lateral extent reaches 2,100 m from the edge of the IHS, which equates to 6,100 m from the Manston runway. The NLN mast, at an assumed height of 305 m agl and the centre of the development site located at approximately 4.33 km from the Manston ARP, will penetrate the conical surface. Figure 4 below provides a plan view of the IHS and Conical Surface at Manston if reopened with the same runway parameters as previously operated; together with the positions of the two communication masts.

4 Instrument Approach: as "a series of predetermined manoeuvres by reference to flight instruments with specific protection from obstacles from the initial approach fix, or where applicable, from the beginning of a defined arrival route to a point from which a landing can be completed and thereafter, if landing is not completed, to a position at which holding or enroute obstacle clearance criteria apply.



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© 2016 Google

Figure 4 Location of the Communication Masts within Lateral Boundaries of Affected Manston OLS (not to scale)

Figure 5 below provides a 2-D side image, from a horizontal perspective, of the extent of the breach of the IHS and Conical Surface created by the two communication masts.



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Figure 5 Illustration of the breach of the Manston OLS created by the two communication masts.

4.5 Conclusions

The OLS for an aerodrome are established based on the criteria described in CAP 168 [Reference 1] contingent upon the runway length and its intended use. Since the OLS is assessed in terms of an Aerodrome Reference Code, Osprey has calculated that, based upon CAP 168 criteria, Manston Airport will have a Code 4 runway. The projected OLS for the airport were subsequently established and assessed in relation to the proposed communication masts and it has been calculated that the two masts will penetrate the Manston IHS (Vigilant) and the Manston Conical Surface (NLN Mast).

The extent of the breach created by the two communication masts is significant. Osprey consider that, if Manston Airport were operational as a Licensed and EASA-compliant airport at the time of planning application for the masts, the safety concerns associated with such a significant breach of its OLS would be so great that, in accordance with its obligations to the CAA to:

“...take all reasonable steps to ensure that ... the aerodrome and its airspace are safe at all times for use by aircraft”.

the airport operator would be required to object to the developments.


Manston Airport Safeguarding Assessment | Manston Instrument Approach Procedures

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5 Manston Instrument Approach Procedures

This section describes the previous Instrument Approach Procedure (IAP) in use at Manston during its most recent operation.

5.1 Runways and Airspace

Manston operated a single asphalt/concrete runway, Runway 10/28. The Airport did have an Aerodrome Traffic Zone5 (ATZ) of circle radius 2.5NM from surface to 2,000 ft above aerodrome level (aal) and accepted aircraft flying Visual Flight Rules6 (VFR) and Instrument Flight Rules7 (IFR) operations. NATS En-Route (NERL) situated within the Terminal Control Room (TC) at the London Area Control Centre (LACC), Swanwick, Hampshire provided radar services for aircraft operating into Manston, until such a time that control of the aircraft could be transferred to the Manston Radar Controllers. Vectoring of aircraft for final approach to the airport by the Manston Controllers was conducted outside of controlled airspace.

There are a number of existing structures near the proposed communication masts. A much smaller mast is located to the north of the Vigilant Mast, which is lit and is 311 ft agl. This existing mast does not penetrate the Manston IHS. To the east of this existing mast is a decommissioned wind turbine, which is approximately 45 m high, only the taller structure (the existing mast) is shown on CAA aviation charts as illustrated in Figure 6 below.

5 ATZ: A circular zone around an airport in which aircraft must obey instructions issued by air traffic control, or must establish to way communications with the controlling authority of the ATZ before entering the airspace. 6 VFR: A set of regulations under which a pilot operates an aircraft in weather conditions generally clear enough to allow the pilot to see where the aircraft is going. 7 IFR: Regulations and rules established to govern flight when due to weather or other conditions flying the aircraft by using outside visual references is not safe. IFR flight depends on flying the aircraft by reference to instruments on the flight deck and eternal electronic signals.



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Data included in this product reproduced under licence from NATS (Services) Ltd © Copyright 2015 NATS (Services) Ltd. All rights reserved.

Figure 6 Existing tall structure to the South of Manston Airport

5.2 Air Traffic Control (ATC) Radar Operations at Manston

Radar operations were previously conducted from Manston utilising an onsite ATC radar system. After the airport’s closure, the radar system was decommissioned and removed. It is envisaged that, should Manston reopen, a replacement radar system will be installed to provide radar surveillance to enhance flight safety in the unregulated airspace surrounding the airport. Radar systems have the potential to create interference to digital radio-relay systems in some situations and vice-versa.

As stated above, Manston Airport will have a responsibility to ensure a safe operating environment is maintained; this includes the electro-magnetic spectrum. The nature of emissions from the communications masts and their alignment are not yet known; the potential technical impact cannot therefore currently be assessed. Any potential effects of radar interference created by the communication masts if they are constructed would have to be considered during the procurement of any new radar system and may influence the nature and cost of the solution. CAP 738 [Reference 4] provides information and guidance on the safeguarding of aerodromes. The purpose of CAP 738 is to offer guidance to those responsible for the safe operation of an aerodrome or a technical site, to help them assess what impact a proposed development or construction might have on that operation. It provides the following information with regard to technical site safeguarding:

“Physical characteristics, such as the size, shape and construction materials, of a proposed development may affect the performance of aeronautical systems at or near an aerodrome. In addition, the siting of telecommunication or other radiating equipment can cause adverse electromagnetic interference to those systems. (For the



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aviation stakeholder concerned) it may be appropriate to approach other aviation organisations, especially where the Air Traffic Services (ATS) are provided by a third party organisation, on the aerodrome to ensure the proposal does not impact on their electronic systems. It is the responsibility of aerodromes with their ATS providers for the technical safeguarding of all of their radio sites for which they hold approvals under the Air Navigation Order [Reference 6]. Where necessary, procedures should be established to meet this requirement. Details of interference safeguarding criteria are outlined in CAP 670, Air Traffic Services Safety Requirements” [Reference 7].

5.3 Instrument Flight Rule Procedures

Procedures are in place at major airports in the UK that describe the standard routes for aircraft to follow on approach or departure from the airport. The majority of aircraft, particularly commercial aircraft flying in and out of Manston, will operate under IFR, which means that they are not reliant on good weather for operations. For airports such as Manston, IFR services may either be:

Instrument Flight Procedures (IFP) – using ground-based or satellite-based systems, the pilot will use on-board instruments to navigate into or out of the airport. Such procedures are designed to specific international criteria and may, or may not, be radar monitored by a controller. Figure 7 below provides an example of a previously utilised IFP for Manston together with the addition of the locations of the two proposed communication masts.

Radar Vectored – a radar controller provides the pilot with headings and altitudes to fly to separate them from other airspace uses and to safely arrive or depart at the airport.



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© Reproduced by permission of the CAA, NATS and OS (not to scale)

Figure 7 Manston IFP and the Location of the two Proposed Communication Masts

Aircraft are normally positioned on the final approach between 8 NM and 10 NM from touchdown for the runway in use. This gives the pilot sufficient time to establish safely and complete final landing checks whilst on course for landing. The oval racetrack area to the north of the proposed communication masts in Figure 7 above is known as a holding area; this is an area where aircraft might be held (dependent on the Manston air traffic activity at the time) before commencing an approach to the runway in use. All of the previous procedures for Manston state aircraft should fly in this holding pattern at an altitude of 3,000 ft above mean sea level (amsl) or as directed. As aircraft leave the hold and continue on the IFP, and once established on final approach, (within 8 to 10 NM) for the runway in use, aircraft would descend in their final approach/landing. The location of the proposed masts, at right angles to the single runway and at a sufficient distance away from the final approach areas would not create a hazard to aircraft in the hold or on final descent towards the runway.



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5.4 Radar Vectored Approaches

Under Radar Vectored Approaches, the controller is responsible for ensuring that the aircraft remains safely clear of terrain and obstacles (this has already been designed into an IFP). To achieve this, minimum altitudes for vectoring in a given area are identified for each unit.

Within the UK IAIP Manston previously published details of a Radar Vectoring Area (RVA). This area is a defined area surrounding an aerodrome and stipulates the height below which aircraft, flying with reference to cockpit instruments, must not descend without instruction from ATC in order to maintain a practical minimum of 1,000 ft separation from the tallest ground obstacle in the given area. The Manston RVA is reproduced below within Figure 8.

© Reproduced by permission of the CAA, NATS and OS

Figure 8 Manston RVA as published when Manston was active



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At the time of production of the chart above, the minimum initial altitude to be allocated by the radar controller within the RVA was 1,500 ft (based on the highest obstacle of 426 ft amsl), except within 5 NM arcs of the TV/Radio masts at 185°/12 NM (797 ft) from the Non Directional Beacon (NDB)(L)8 known as MTN, when the minimum altitude is 1,800 ft; and 261°/14 NM (686 ft) from the NDB (L) MTN, when the minimum altitude is 1,700 ft.

5.5 Application of the RVA at Manston Airport

In November 2007, the International Civil Aviation Organisation (ICAO) introduced new requirements for the application of minimum altitudes provided to aircraft receiving an ATC Service. A new charting standard was introduced for the depiction of minimum altitudes issued by ATC providing a radar surveillance service under the title Air Traffic Control Surveillance Minimum Altitude Chart (ATCSMAC). The purpose of the ATCSMAC is to provide information that will enable flight crews to monitor and cross check altitudes assigned whilst receiving vectoring instructions from air traffic controllers.

The UK defines a Surveillance Minimum Altitude Area (SMAA) as follows:

‘A Surveillance Minimum Altitude Area is a defined area in the vicinity of an aerodrome, in which the minimum safe levels allocated by a controller vectoring IFR flights with Primary and/or Secondary Surveillance radar equipment have been predetermined.’

CAA CAP 777 ATC Surveillance Minimum Altitude Charts in UK Airspace Policy and Design Criteria [Reference 8] describes the purpose of the SMAA as follows:

To relive controllers of the responsibility for determining the appropriate minimum safe levels; and

To provide pilots with an indication of the minimum altitudes which ATC will allocate when vectoring an aircraft below the published Minimum Sector Altitude (MSA).

5.6 Communication Transmitters Fresnel Zone

The Fresnel Zone is a cylindrical ellipse drawn between a transmitter and receiver. The size of the ellipse is determined by the frequency of operation and the distance between the two sites. As the alignment of the communications masts and the nature of their transmissions are not known; the degree of protection required cannot therefore be assessed. Once these facts are known, an assessment should be made as to whether an aircraft, particularly a large commercial aircraft, passing through the masts’ Fresnel Zone close to the origin of the transmitter/receiver would have a detrimental effect on the performance of the system. Any need to avoid either communication masts’ Fresnel Zone would have a significant impact on both IFR and VFR procedures.

5.7 Terrain/Obstacle Clearance Criteria

The minimum altitude available to ATC for vectoring arriving flights within the SMAA is 300 metres (m) (984 feet (ft)) above the highest obstacle within the SMAA or 8 NDB: A radio transmitter at a known location, used as an aviation navigational aid, each NDB is identified by a one, two or three letter Morse code callsign.



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SMAA sector. However, the minimum altitude for any SMAA, or SMAA sector shall not, unless dispensation is granted for exceptional operational reasons, be less than 1500 ft above the published aerodrome elevation, in compliance with the UK requirement that aircraft shall be vectored to join final approach at no less than 5 NM from touchdown.

The minimum altitude available within the SMAA, or SMAA sector, is determined by reviewing obstacles within the boundary of the SMAA, or SMAA sector. It is possible for an aircraft to stray from the SMAA undetected by the pilot or the controller; consequently, obstacles outside the SMAA need to be considered when calculating minimum altitudes for use inside the SMAA. This area is referred to as a Primary SMAA Buffer (PSB) and attracts a full Minimum Obstacle Clearance (MOC) value of 300 m (984 ft). The width of the PSB is dependent on the Surveillance radar lateral separation certified for use with the ATCSMAC, which for Manston was assumed to be 5 NM. Once completed, the addition of 300 m (984 ft) to the elevation of the highest obstacle within the resultant area, buffer or sector will determine the minimum initial altitude available. The resultant figure is then rounded up to the nearest ‘hundreds of feet’. Table 1 below provides the individual mast details when considering any impact to the RVA/SMAA if re-established at Manston.

Mast Height of Mast (m/ft) agl

Land Elevation (m/ft)

Altitude of Mast (ft) amsl, (Rounded up to nearest 10 ft)

Addition of 984 ft obstacle clearance criteria (ft)

Rounded up to nearest 100 ft. Minimum Altitude Available

Vigilant 322/1,056.43 1/3.28 1,060 2,044 2,100

NLN 305/1,000.66 2/6.56 1,010 1,994 2,000

Table 1 Calculation on Assessing Impact to the Manston RVA if the Masts are constructed.

Figure 9 below illustrates the location of the communication masts if constructed. The addition of the masts would require an increase of the minimum vectoring altitude of the RVA in the region of the masts to be increased from 1,500 to 2,100 ft in order to provide the required clearance between aircraft in receipt of an IFR service from ATC and the top of the mast structure. This increase in the sector height may be achieved by the addition of an additional fillet of airspace surrounding the masts of 2,100 ft.



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© Reproduced by permission of the CAA, NATS and OS

Figure 9 Manston RVA with inclusion of the highest altitude of the communication masts (not to scale)

5.8 Conclusions

A significant addition to the minimum vectoring altitude may create an impact on the design of any new IFPs for the airport and may affect any decision on suitable holding heights. This, in turn, could result in more aircraft being routed to the north of the airport thereby increasing the environmental impact of noise over more built-up areas.

When providing vectors to departures controllers will have to ensure aircraft routing within 5 miles of the mast are at least 2,100ft otherwise they will have to be routed around the area. When vectoring aircraft into Manston radar controllers would have to restrict the descent of aircraft to 2,100ft until 5 miles clear of the communication masts.

While it would appear that the potential impact of the proposed mast developments on IFR procedures could be managed safely, they would have an operational impact on Manston Airport procedures which could result in aircraft overflying built up



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areas more frequently. While this may not in itself constitute grounds for objection to the development, it adds weight to objection on the grounds of the OLS penetration.


Manston Airport Safeguarding Assessment | Manston Visual Circuit Procedures

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6 Manston Visual Circuit Procedures

The following section considers the impact the two communication masts may create to visual procedures conducted at Manston.

6.1 Overview

If weather conditions and operating rules allow, both Commercial and non-commercial flights will frequently be conducted visually, under VFR, as this can represent the most efficient and flexible method to arrive at or depart from the airport.

Aircraft operating under VFR do so within Visual Meteorological Conditions (VMC). CAP 493 Manual of Air Traffic Services – Part 1 [Reference 9] stipulates the weather criteria for aircraft to operate under VFR; within Class G uncontrolled airspace, in which Manston is located, aircraft are required to remain clear of cloud and in sight of the surface at all times and are ultimately responsible for their own terrain and obstacle clearance, as well as separation from other aircraft.

Previous operations at Manston included the operation of light aircraft and a flight training company that had been based at the aerodrome for 30 years before its closure and an enforced move to Lydd Airport. British Airways had selected Manston Airport as a base to conduct flying training on its Airbus A380 and Boeing B787aircraft [Reference 10] and from July 2013, the first of the flights took place with the A380.

6.2 Manston Visual Circuit Operations

Manston operated a VFR visual circuit to the south and north of the airfield for both runway directions. Details of visual circuit procedures were previously included within the UK IAIP [Reference 3] which for noise abatement reasons were more restrictive for all jet aircraft and those aircraft exceeding 5,700 kg Maximum Take Off Weight (MTOW); these circuits were flown at a height of 1,800 ft aal. For all other aircraft not subject to Noise Abatement Procedures, circuits were flown at 1,000 ft aal. The procedures for aircraft joining the visual circuit and subject to Noise Abatement Procedures were as follows:

Runway 28 Left-Hand Circuit: Climb on runway heading until circuit altitude/height before turning crosswind. Base leg over the sea. Maintain circuit altitude/height until on final approach, then descend on the equivalent of a 3° glidepath.

Runway 28 Right-Hand Circuit: Climb on Noise Preferential Routeing until at circuit altitude/height and 5 DME (I MSN). Crosswind, downwind and base legs are to be flown over the sea. The downwind leg should be aligned parallel to and 3 nm or more from the runway centre-line. Maintain altitude/height until on final approach, then descend on the equivalent of a 3° glidepath.

Runway 10 Left Hand Circuit: Climb on a runway heading until circuit altitude/height, the heading to be maintained until the crosswind leg can be



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achieved over the sea. Downwind leg over the sea aligned parallel to and 3 nm or more from the runway centre-line. Base leg to be flown in such a way as to avoid densely populated areas. Maintain an altitude/height until on final approach, then descend on the equivalent of a 3° glidepath.

Runway 10 Right-Hand Circuit: Climb on a runway heading until circuit altitude/height, the heading to be maintained until the crosswind leg can be achieved over the sea. Thereafter the downwind and base legs are to be flown in such a way as to avoid densely populated areas. Maintain altitude/height until on final approach, then descend on the equivalent of a 3° glidepath.

6.3 Impact Created by the Communication Masts on Visual Circuit Operations

At Manston, aircraft are required to climb to a height of 1,000 ft aal to join the visual circuit (1,800 ft for all jet aircraft and those aircraft exceeding 5,700 kg MTOW). Aircraft turning downwind in the southerly visual circuit would turn onto a track, which would take aircraft directly towards both masts. The Standardised European Rules of the Air (SERA) took effect across Europe in December 2014 [Reference 11]. The rule (known as the 500 ft rule) is included within the Official Journal of the European Union Regulation (EU) No 923/2012 and states that:

….”except when necessary for take-off and landing, or except by permission of the competent authority, a VFR flight shall not be flown at a height less than 500 ft above the ground or water, or 500 ft above the highest obstacle within a radius of 500 ft from the aircraft”.

To the north and north east of Manston lie the traditional seaside towns of Margate, Broadstairs and Ramsgate, the noise abatement and visual circuit procedures previously published by the airport were established to keep the noise footprint of aircraft to a minimum over these populated areas. The ground track of the visual circuit to the south of the aerodrome was over less densely populated areas consisting of marshland and land used for industrial means, and was therefore the preferred direction of circuit for General Aviation9 (GA) aircraft and possibly commercial and training aircraft. However, even whilst flying the southerly circuit and to avoid areas of population, aircraft would fly to the south of the villages of Cliffs End, Minster and Monkton, keeping the circuit as tight as was required to keep the runway in sight.

Aircraft climbing to 1,000 ft aal to join the southerly visual circuit would not achieve the 500 ft vertical avoidance required from both communication masts (aircraft would be at the same/lower height of the masts) and would have to climb or adjust course laterally to avoid the masts by 500 ft. To follow the 500 ft rule aircraft would likely climb in the visual circuit to 1,600 ft if weather conditions and the absence of low cloud permits or avoid the masts laterally, taking them further from the airport. The construction of the masts would create obstacles which can be difficult to visually acquire from the air especially in marginal weather conditions and particularly whilst undertaking busy and critical stages of flight, such as an approach to land or immediately after departure. Although minimum clearance of both the

9 General Aviation: General aviation covers a large range of activities, both commercial and non-commercial, including flying clubs, flight training, agricultural aviation, light aircraft manufacturing and maintenance.



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masts might be achieved laterally, human factors, emergencies, poor visibility, avoidance of populated areas, pilot error and distraction could lead to a potentially unsafe situation.

6.4 Aviation Objections

A number of objections to the Vigilant Mast have been lodged with the Dover District Council (the NLN Mast is not yet within the planning system). A selection of these, which support Ospreys assessment, have been included below.

A private pilot and regular user of Manston has stated within objection to the Vigilant Mast [Reference 12] that the old cooling towers (which were directly to the east of the location proposed for the Vigilant Mast) were overflown as the aircraft flew downwind in the circuit. Such visual markers are often used in circuit flying. This provides evidence that the location of the Vigilant Mast (and the adjacent planned location of the NLN Kings Head Farm Mast) would be overflown during normal circuit operations conducted to the south of the aerodrome.

A Director of the Aircraft Owners and Pilots Association (AOPA) has objected to the Vigilant Mast [Reference 11]. AOPA represent the interests of pilots operating all types of flying machines ranging from GA to commercial airliners. The detailed AOPA objection includes in reference to visual circuit operations at Manston that:

….”A visual manoeuvring area covers the last part of an aircraft's approach to an Airport and its subsequent landing without the use of precision air navigation aids. It can be seen that, for noise abatement and environmental reasons, this area will be restricted to the south of the Airport to avoid flights passing over the population centres of Broadstairs, Margate and Ramsgate. The proposed mast with its guy wires lies within a critical part of this area and their physical features are such that they would be difficult to see, in spite of any markings which they may have, by pilots flying at low level, especially in conditions of reduced visibility”.

6.5 Visual Circling Operations

For both training and operational reasons it may be necessary for a pilot to make an IFR instrument approach to one runway before converting to a VFR circling manoeuvre to land in the opposite direction. An example might be if a navigation aid (such as the Instrument Landing System) on Runway 10 is unserviceable but the wind conditions dictate that the pilot cannot safely land on Runway 28; in which case the pilot would fly an IFR approach to Runway 28 until visual with the airport then manoeuvre visually (under VFR) to land on Runway 10. To protect this procedure the Visual Manoeuvring (Circling) (VM(C)) Obstacle Clearance Altitude (OCA) must also be considered. This provides the minimum safe altitude in terms of obstacle clearance when executing such a manoeuvre, and is determined based upon a survey of dominant obstacles within the vicinity of the runway, as detailed in CAP 232 Aerodrome Survey Information [Reference 5]. The maximum Survey Area stipulated extends to a range of 6.94 NM (approximately 12.9 km) from the operational runway’s threshold.

The incidence of aircraft performing this manoeuvre is likely to be low. Nonetheless, with the exception of small GA aircraft, construction of the communication masts would require this circling area to be restricted to an area north of the aerodrome leading to an additional aircraft noise footprint over populated areas.



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6.6 Search and Rescue Operations

During 2013, Manston Airport was selected as a location for the new ten year Search and Rescue (SAR) contract, operated by Bristow helicopters on behalf of the Maritime and Coastguard Agency (MCA). These plans were cancelled after the airport’s closure was announced. The introduction of the obstruction created by the communication masts to the aerodrome environment would add a further complication for all aircrews, but particularly for SAR crews when time is of the essence for SAR activities, most of which are conducted at low altitude. SAR require the most direct routing to be effective and the introduction of the masts and associated guide wires will introduce an obstruction if SAR aircraft were to be based at Manston Airport.

6.7 Conclusions

Aircraft operating in the southerly Manston visual circuit would be confronted by the masts as they turn downwind within the circuit; aircraft are legally obliged to avoid such obstructions by 500 ft, either laterally or vertically. The construction of the communication masts would create obstacles which can be difficult to visually acquire from the air especially in marginal weather conditions and particularly whilst undertaking busy and critical stages of flight, such as an approach to land or immediately after departure.

Aircraft flying the preferred ground track of the southerly visual circuit at the previous circuit height of 1,000 ft aal would be unable to achieve the required vertical separation of the masts. Minimum clearance of both the masts might be achieved laterally by altering the course of the circuit further south. However, flying a wider circuit would increase fuel burn, increase the noise footprint to a wider area and away from the immediate area of the aerodrome and is unlikely to be suitable for all aircraft.

The use of the northerly circuit would reduce the impact created by the masts; however, the exclusive use of the northerly circuit will concentrate the noise footprint and other environmental effects over a populated area used for tourism and recreation.

Changes to the VFR circuit to address the safety issues associated with the masts would introduce other safety issues as a result. For example, if the circuit height was increased unqualified pilots may inadvertently enter cloud; to mitigate this the visual circuit may more often be declared closed thereby reducing the commercial attractiveness of the airport. Equally, if the circuit size was increased to route around the obstructions, aircraft that encounter a problem whilst flying downwind, will not be able to turn into the airfield until they are certain of remaining clear of the masts.

It could be argued that the impact of the communication masts on VFR operations could be mitigated by changing the height, route or direction of the visual circuit. However, such would be the potential increase in noise footprint associated with such mitigations; the introduction of new safety hazards associated with such large obstructions so close the airport; and the operational limitations they would place on commercial, non-commercial and potentially SAR operations at the airport, their impact on operations at Manston airport would be disproportionate.



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Manston Airport Safeguarding Assessment | Manston Airport - Airspace

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7 Manston Airport - Airspace

This Section considers the impact the two communication masts may create to Manston’s prospects of reinstating the Aerodrome Traffic Zone (ATZ) and the anticipated CAA airspace change requirement.

7.1 Overview

Kent International Airport did have an ATZ of circle radius 2.5NM from surface to 2,000 ft aal published within the UK IAIP [Reference 3]. The purpose of the ATZ is flight safety based as aircraft wishing to operate within the ATZ must have specific clearance from ATC to enter and operate within it. ATZs are usually, although not exclusively, established at aerodromes that cater for public transport flights and offer a degree of protection to aircraft flying in the visual circuit and near the aerodrome. An ATZ at Manston Airport would provide a degree of Air Traffic Management (ATM) to the airspace immediately surrounding the airport as aircraft would be required to obtain permission of ATC to enable the flight to be conducted safely within the zone.

7.2 Purpose of an ATZ

The purpose of an ATZ is to provide an appropriate degree of protection to aircraft during the flight-safety critical stages of take-off, landing and circuit flying. Its role is to protect the safety of flight operations rather than the airport procedures per se; these are protected under separate regulations and processes.

Although aircraft within an ATZ must obey the instructions of the tower controller (if present), or must make radio contact before entering the ATZ, there is no pre-requisite for any form of ‘control service’ when granting permission for an ATZ; the pilot remains responsible for their safety (including terrain and obstacle clearance) while operating in the ATZ.

The ATZ is not in itself a separate classification of airspace, it conforms to the Class of Airspace in which it is situated; in the case of Manston Airport, this is Class G Airspace. The CAA guide to VFR flight states that:

‘Within Class G airspace, regardless of the service being provided, pilots are ultimately responsible for collision avoidance and terrain clearance, and they should consider service provision to be constrained by the unpredictable nature of this environment’.

The British Gliding Association provides a helpful working interpretation of the purpose of the ATZ:

‘…the aim of an ATZ is to provide a degree of protection to traffic in the immediate vicinity of an aerodrome. That said, ATZs are not established with the aim of providing segregation between various (and potentially disparate) operations but



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with the goal of enhancing the safe integration of these in the immediate vicinity of an aerodrome’10.

7.3 Application Process

All airspace changes are unique and, regardless of scale, will require some form of consultation. Applications for new ATZs are processed in accordance with CAP 724 (Airspace Charter), Appendix G relating specifically to ATZs [Reference 13]. The qualifying criteria and the provisions for the establishment of ATZ are contained in Rule 45 of the Rules of the Air Regulations 200711. Airspace change proposals must be handled according to the standard published process in order to convince the Head of CAA Safety and Airspace Regulation (SARG), of the need for, and merits of, the proposed change. Following confirmation of eligibility, the SARG will carry out actions as listed within CAP 724. For ease of reference, these actions are reproduced below:

Visit the unit applying for the creation of the ATZ and any other aerodrome or aviation activity site that might be affected by the planned ATZ. The purpose of the visit(s) is to gather information on the respective levels of activity, including, where available, movements data together with any co-ordination procedures (MOU, LOA) that might exist. Obtain copies of extant documents in order to provide evidence of co-ordination for future use.

Determine the appropriate size of the new ATZ in accordance with Article 258 of the Air Navigation Order and establish the hours of operation of the ATC, AFISO or A/G Unit.

Establish the aerodrome reference point, normally the centre of the longest runway or for grass airfields, and the centre of the landing area.

Liaise with Surveillance & Spectrum Management (S&SM) for frequency allocation requirement. (Note: when an ATZ is dis-established the continued requirement for the frequency is to be reviewed and S&SM informed if no longer needed.)

Controlled Airspace Section - ensure that the proposed ATZ is clear of established or planned controlled airspace.

Other airspace reservations - ensure that the proposed ATZ is clear of other notified areas, danger areas, restricted areas, HIRTA12s etc.

Other aerodromes - determine if the new ATZ lies close to another aerodrome or overlaps an associated ATZ or MATZ13. Consider the need for operating agreements with adjacent aerodromes or activity centres.

Aerodrome traffic patterns - determine if the new ATZ affects the established IFR or VFR traffic patterns of other aerodromes.

Obtain statistical evidence of existing unit based movements and adjacent unit movements, taking into account the type of ac involved, which together justify the establishment of an ATZ to create a known traffic environment.

10 British Gliding Association ‘How well do you know ATZ procedures?’ 11 http://www.legislation.gov.uk/uksi/2007/734/pdfs/uksi_20070734_en.pdf 12 HIRTA: High Intensity Radio Transmission Area. 13 MATZ: Military Aerodrome Traffic Zone, established at military aerodromes for the protection of military traffic in the critical stages of circuit, landing and take-off.

http://www.legislation.gov.uk/uksi/2007/734/pdfs/uksi_20070734_en.pdf



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Military low flying system - determine what, if any, impact the new ATZ will have on military low level operations.

Other airspace considerations - determine if there is any other aviation activity (gliding, parachuting, microlight site etc.) in the vicinity of the proposed ATZ.

Where necessary, act as a mediator to resolve conflicting interests. Conduct a Case Study including consideration of DAP Regulatory Requirements. When the above co-ordination has been completed, promulgate to NATMAC14

via a Consultative Letter. Establish a date for the activation of the new ATZ and promulgate in the UK

IAIP. Where the ATZ is associated with the granting of an aerodrome licence DAP will liaise with the Safety Regulation Group. Wherever possible, agree sufficient advance warning to allow use of the AIRAC15 cycle.

Submit Form 933 to NATS (AIS) to appropriately update the UK AIP and VFR Charts.

Importantly, while the process above assesses the impact of the ATZ on adjacent aerodromes and other airspace users, it would not specifically take into account issues around obstacle clearance associated with the presence of the Vigilant or NLN communication masts.

7.4 Conclusions

As pilots are required to obtain permission before entering an ATZ, the purpose of an ATZ at Manston Airport would be to ensure that any aircraft passing within 2.5nm and below 2000ft aal contacted the resident ATC before entering the zone. This will allow their flight to be deconflicted from those departing, arriving or flying in the vicinity of the airport.

Importantly, the ATZ is not intended to provide separation from terrain or obstacles. While the airports Instrument Flight Procedures for departing and arriving aircraft will provide such separation, the classification of surrounding airspace applies to other operations within the ATZ; as Class G airspace, this places responsibility for terrain clearance on the pilot.

Reflecting this delineation of responsibilities for terrain and obstacle clearance, the process outlined in CAP 724 would not specifically take into account the Vigilant and NLN communication masts when considering whether an ATZ were approved. However, the masts would have such an operational impact on IFR procedures and such a significant operational and safety impact on VFR procedures, the case for establishing an ATZ would be undermined.

14 NATMAC: National Air Traffic Management Advisory Committee, provides a panel representatives from all aspects of aviation who advise DAP on all airspace requirements. 15 AIRAC: Aeronautical Information Regulation and Control, revision of operationally significant changes in information. These changes are received well in advance so that users of aeronautical data can make necessary amendments.


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8 Conclusions

8.1 Overview

This section summarises the assessment of the impact of the proposed Richborough Power Station (Vigilant) and Kings End Farm (NLN) communication masts on Manston Airport operations were the airport to be reopened and licensed in accordance with CAA and EASA Regulations.

8.2 OLS

On establishing the lateral and vertical confines of the potentially affected OLS for Manston Airport, it has been assessed that the communication masts will penetrate the IHS (Vigilant) and the Conical Surface (NLN Mast). The presence of such a severe penetration of the OLS could adversely impact Manston Airports plans for Licensed Aerodrome status and EASA compliance.

The extent of the breach created by each mast is significant; it is considered that if Manston Airport were already operational, safety concerns associated with such a significant breach so close to the airport, would result in an objection by the airport operator.

8.3 Instrument Procedures/Radar Vectoring Area

The addition of the communication masts would require the minimum vectoring altitude of the RVA in the region of the masts to be increased from 1,500 to 2,100 ft. Any addition to the minimum vectoring altitude may create an impact on the design of any new IFPs for the airport and may affect any decision on suitable holding heights. They would also need to be taken into account by radar controllers at Manston when vectoring aircraft in the vicinity of the Airport.

Though not in itself grounds for objection to the proposal, there would be an impact of the mast development on Manston Airport IFR operations.

8.4 Visual Circuit Operations

Aircraft operating in the southerly Manston visual circuit would be confronted by the masts as they turn downwind within the circuit; aircraft are legally obliged to avoid such obstructions by either 500 ft laterally or vertically. The construction of the communication masts would create obstacles which can be difficult to visually acquire from the air especially in marginal weather conditions and particularly whilst undertaking busy and critical stages of flight, such as an approach to land or immediately after departure.

To address this hazard the circuit height could be increased or the track of the visual circuit extended to the south; however, both these measures introduce new safety hazards to VFR operations at Manston Airport. The use of the northerly circuit would reduce the impact created by the communication masts; however, the exclusive use of the northerly circuit will concentrate the noise footprint and other



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environmental effects over a populated area used for tourism and recreation. Equally, the presence of such large obstructions so close to the airport would constitute an enduring hazard to VFR operations, particularly SAR operations should they move to Manston Airport.

If Manston Airport were operational, the residual safety impact on VFR operations, despite implementation of mitigation measures, would likely result in an objection by the airport operator.

8.5 ATZ

The purpose of an ATZ at Manston would be to provide protection to aircraft departing, arriving or flying in the vicinity of the airport by ensuring that any aircraft in the immediate vicinity of the airport is required to contact ATC.

Its purpose is not to ensure terrain and obstacle clearance to either IFR or VFR operations (including the visual circuit); these are covered under other regulations. Therefore, although the process outlined in CAP 724 takes into account a range of factors when considering whether an ATZ should be granted, it would not take into account the Vigilant and NLN mast developments. In theory, the proposed communication masts would have little impact on Manston Airport’s application for an ATZ. However, in practice their operational impact on IFR procedures and significant operational and safety impact on VFR procedures, undermines the case for establishment of an ATZ.



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9 References

Reference Name Origin

1 CAP 168 Licensing of Aerodromes

Version 10

7 March 2014

CAA

2 CAP 793 Safe Operating Procedures at Unlicensed Aerodromes

First Edition

July 2010

CAA

3 National Air Traffic Service Aeronautical Information Service

UK Integrated Aeronautical Information Package

AIRAC 04/2016

NATS AIS

4 CAP 738 Safeguarding of Aerodromes

Version 2

December 2006

CAA

5 CAP 232 Aerodrome Survey Information

Version 3 Amdt 01/2008

February 2008

CAA

6 CAP 393 Air Navigation: The Order and the Regulations

Version 4.1

April 2015

CAA

7 CAP 670 ATS Safety Requirements

Version 3 Incl Amdt 1/2014

May 2014

CAA

8 CAP 777 ATC Surveillance Minimum Altitude Charts in UK Airspace Policy and Design Criteria

Version 3

July 2013

CAA



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9 CAP 493 Manual of Air Traffic Services Part 1

Version 6.1 Corrigendum

April 2015

CAA

10 BA picks Manston for B787 and A380 Training

http://www.airport-world.com/news/general-news/2773-ba-picks-manston-for-b787-and-a380-training.html

Accessed 6 April 2016

Airport World

11 www.caa.co.uk/sera

Accessed 6th April 2016

CAA

12 Dover District Council

Planning Applications Search

https://planning.dover.gov.uk/online-applications/applicationDetails.do?activeTab=consulteeComments&keyVal=DCAPR_228292

Accessed 6th April 2016

Dover District Council

13 CAP 724 Airspace Charter

Version 4 Amdt 2012/001

August 2012

CAA

Table 2 Table of References




http://www.caa.co.uk/sera






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A1 CAA Approved Procedure Designer Report

A1.1 Overview

A review was performed of the previously published flight procedures for Manston, and given the desire to reopen for commercial passenger/freight flights a consideration of future likely procedures was also taken. The reviewer is a current commercial pilot, CAA approved Instrument Flight Procedure Designer, and flying examiner/instructor. To recreate all the Manston IFP designs would be a considerable piece of work, therefore the experience of the reviewer of where the protection areas would likely go was taken in a broad sense. It is believed that a number of areas will be impacted.

A1.2 Instrument Departure Procedures

Airports that cater for larger commercial aircraft generally have published routes that a departing aircraft follows, or issue instructions to the pilots. The design of these takes into account the terrain, the obstacles in the vicinity of the airport, impact of noise on the local communities, and connection to the air routes that the aircraft climb- up and joins to the en-route air traffic structure. An aircraft taking off from Runway 10 on a commercial flight following Instrument Flight Rules (IFR) is required to have sufficient climb performance to clear obstacles by a set margin. This applies to both pilot instructions and published Standard Instrument Departure (SID) procedures. The most noise preferable departure from Manston is to keep clear of overflying the built up areas of Margate, Broadstairs, Ramsgate, Herne Bay, etc.

In addition, to the south of Manston a number of air routes join up and route via the Dover area to both the continent and back over the UK for transatlantic flights. This is a busy area for all commercial traffic flying at higher levels and as such aircraft departing from Manston will need to be manoeuvred to ensure that they can join the sequences of traffic already in the airspace structure. A commercial multiengine aircraft must be able to climb at a gradient of 3.3% while still coping with one of the engines being inoperative. All obstacles must be less than 0.8% below this slope, or in other words, not higher than a 2.5% gradient.

An aircraft taking off from Runway 10 and turning south to avoid Ramsgate would have approximately 2.5 NM to the proposed (if there was a restriction on not turning before the end of the runway) Vigilant Mast, assuming the turn would be made at approximately 500 ft. If the aircraft then suffered an engine failure and climbed at 3.3%, it would reach the mast at approximately 1,000ft. This would be below the required level to clear the mast safely. A strong wind from the north would result in the aircraft arriving at a lower level adjacent to the mast. Without a restriction on turning south before the runway end the distance to the mast would be reduced to approximately 2 NM and the aircraft would reach the mast lower than 1,000ft.

In order to overcome this, the airport would need to introduce a published route known as a Standard Instrument Departure (SID), or issue instructions that the



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aircraft fly a set distance over and past Ramsgate before turning. It is likely, due to the design constraints for the routes, that the departure procedure would need to take the aircraft over the top of Ramsgate.

An aircraft suffering an emergency that required an immediate landing back would either need to have an extended routing, or fly to the north over the built up areas as a turn towards the mast would not be prudent.

In summary, the proposed mast constrains the departure procedures, which may well impact on noise levels for the surrounding towns, and/or increase route lengths, and fuel costs to aircraft. It may constrain options following an emergency return to the airport. These impacts are for departures from both runway ends but the noise impacts will be greater for Runway 10.

A1.3 Aircraft Holding Pattern

The lowest aircraft directed holding level available to an aircraft to fly the racetrack shaped holding procedure is currently 2,000 ft. Aircraft would need to fly at an altitude of at least 1,000 ft above the mast; this would increase the lowest hold level to 2,100 ft. The controlled airspace to the west of Manston which overlaps with Runway 10 hold protection has a bottom level of 5,500 ft and is used for commercial aircraft arrivals/departures from the London airports. Aircraft holds would normally be no closer vertically than 500 ft to the controlled airspace. This would mean that the number of available levels for holding aircraft would be reduced from four to three as aircraft in the hold must be spaced at 1,000ft separation. However, it is likely that the hold position could be moved, this may impact on the track miles an aircraft has to fly, or the flexibility of the operation.

A1.4 Visual Manoeuvring Procedures following an Instrument Approach

With the exception of small light aircraft all the visual manoeuvring procedures would need to restricted to flying on the north side of the airport. This would have a noise impact on this more densely populated area. These procedures would not be flown very often if it is assumed that the airport will reinstall all the same radio navigation aid equipment that it had previously.

A1.5 Aircraft Flying Visual Circuits

The proposed mast is in the vicinity of where aircraft are likely to fly circuit procedures. These procedures are used when training pilots to land for their pilot licence, or if learning to fly a larger or different type of aircraft. An experienced pilot flying a small light aircraft could avoid the mast in normal circumstances. However, it could prove a challenge for a student pilot, and given the risk it would be likely that pilot instructors would insist on students flying the circuit pattern to the north which would create an additional noise foot print over the more built up area.

While flying circuits in a single engine aircraft there should be a reasonable prospect of landing the aircraft back on the runway if the engine were to fail. This often entails flying the shortest path back towards the airport and flying a shortened circuit pattern. The mast could well form an obstacle between the aircraft and the airport in this scenario.



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Larger commercial aircraft are fitted with terrain warning systems, the position and height of the mast could well trigger these warning systems, which would cause a distraction to the crew, which may result in a decision to fly to the north of the airport or flying further south over Sandwich.

A1.6 Other Airfield Examples

There are examples of TV masts close to unlicensed small airfields in the UK, for instance, at Membery airfield. These airfields do not need to meet the safety standards of a licensed aerodrome and are generally used for recreational flying in light aircraft, microlight aircraft, and gliders. It is not considered prudent to train pilots at these types of locations, and until recently all training for pilot light aircraft licenses was required to be undertaken at a licensed aerodrome which has an obstacle safeguarding policy.

Flying at these types of unlicensed aerodromes assumes that the pilot accepts a higher level of risk, and that the risk is mainly on the pilot, because the risk to third parties on the ground is very small for these types of small aircraft. However, for larger commercial aircraft, the risk to third parties on the ground is different and the duty to protect paying passengers is to a far higher standard. For these reasons the safeguarding of obstacles in the vicinity of an airport, such as Manston, must be performed to a higher standard. Counter arguments based on examples of small unlicensed aerodromes are therefore not appropriate to a Manston Airport type of operation.

A1.7 General Comments on OLS

The safeguarding of the obstacle environment around an airport is to ensure the safety of the aircraft, and therefore by default the local communities surrounding the airport. Often arguments are developed around normal operations of aircraft in good weather to justify a penetration of the surfaces. However, the aim of the surfaces is in addition to ensuring safety of normal operations to also cater for emergency situations. For large commercial aircraft, these extremely rare events can have huge impacts, so need to be considered fully if the OLS are penetrated.

A1.8 Summary

The proposed mast will impact on the operations of Manston Airport if it were to reopen for commercial aircraft as the position would restrict some operations in the area to the south. It is likely that there would be greater overflight and noise for the main built up areas of Margate, Broadstairs, Ramsgate, and Herne Bay.


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A2 Osprey Brief Résumés

A2.1 Overview

Background information on the Osprey personnel who have compiled and completed peer review of the assessment is provided below.

Author

The Author is a Senior Consultant of Osprey CSL and has over four years’ experience in performing impartial, independent assessments of the potential impact of both onshore and offshore wind farms for wind energy developers, airports and local planning authorities; currently examining, planning and validating airspace mitigation measures in support of the UKs renewable policy. Previously he completed 34 years of exemplary service and extensive expertise in all disciplines in Air Traffic Control and Airspace Management in the Royal Air Force in the role as Air Traffic Controller. The author is a highly capable aviation professional who possesses a wealth of operational and managerial experience and is a Subject Matter Expert who on Aviation Safety Assessments and analysis of developments to impact air traffic service provider operations and airfield safeguarding criteria including obstacle limitation surfaces.

Reviewer

The Reviewer joined Osprey in July 2012 after a period of seven years at the CAA. During this position, he was lead point of contact for airspace planning and regulation of offshore operations, including navigation and communications infrastructure to support safe and efficient air traffic operations. He has excellent communication and organisational skills, particularly in the Airspace Change Process (ACP) Prior to the position at CAA the reviewer had 28 years RAF aircrew experience; 25 of those in fast jet operations worldwide.

Approver

The Approver has recently joined Osprey after 27 years as an air traffic controller in the Royal Air Force. In his most recent appointment, he was seconded to the CAA, initially as Assistant Direct of Airspace Policy 2 at the Directorate of Airspace Policy and then, on the formation of the Safety and Airspace Regulation Group, as Deputy Head of the Intelligence Strategy and Policy Division where he was responsible for all CAA Safety Policy development and oversight of its major programmes including Spaceplanes, Unmanned Air Systems and State Safety. An excellent problem solver and negotiator, he was also heavily involved in managing the diverse requirements of civil and military stakeholders during the London 2012 Olympics and holds qualifications in strategic management, strategic direction and leadership and project management.

Documents

Manston Airport Safeguarding Assessment · Author Osprey CSL Reviewer Osprey CSL Approver Osprey CSL . ... established and assessed in relation to the proposed communications masts