Walney Extension Offshore Wind Farm TMZ Final Report on the Stakeholder Consultation · 2017-03-23 · Walney Extension Offshore Wind Farm TMZ – Final Report on the Stakeholder

Date: 30 January 2015

Revision: Issue 1

Osprey Ref: 70791 020

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Walney Extension Offshore Wind Farm TMZ – Final Report on the Stakeholder Consultation

Walney Extension Offshore Wind Farm TMZ – Final Report on the Stakeholder Consultation | Document Details

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Document Details

Reference Description

Document Title Walney Extension Offshore Wind Farm TMZ – Final Report on the Stakeholder Consultation

Document Ref 70791 020

Issue Issue 1

Date 30 January 2015

Walney Extension Offshore Wind Farm TMZ – Final Report on the Stakeholder Consultation | Glossary

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Executive Summary

DONG Energy is the Sponsor for a proposed airspace change over the existing operational Walney Offshore Wind Farms (1 and 2), the Walney Extension Offshore Wind Farm, West of Duddon Sands (WoDS), Ormonde and Barrow Wind Farms, located northwest of Morecambe Bay in the Irish Sea.

As part of the Civil Aviation Authority’s (CAA) Airspace Change Process (ACP)(CAP 725) [Reference 1], DONG Energy is required to submit a case to the CAA to justify the establishment of a Transponder Mandatory Zone (TMZ) over the existing Walney, WoDS, Ormonde and Barrow Wind Farms and the Walney Extension Offshore Wind Farm, and to undertake a consultation exercise with all relevant stakeholders. This ensures that all stakeholders who may be affected directly or indirectly by the proposed change are consulted, as well as highlighting any environmental impacts that the proposed airspace change may have.

DONG Energy has engaged Osprey Consulting Services Ltd (Osprey) to project manage the ACP on their behalf.

This document is a Final Report on the consultation carried out by DONG Energy between 10th October 2014 and 11th January 2015 in accordance with the requirements of CAA CAP 725 [Reference 1]. It includes an analysis of all submissions received throughout the consultation and identifies the main issues raised by consultees. It also provides DONG Energy’s views in relation to the issues raised and outlines post-consultation action taken, or planned to be undertaken by DONG Energy.

This document will form part of the Airspace Change Proposal submission to the CAA that will detail the case for the proposed TMZ.

Subject of the Consultation

The purpose of this consultation was to gather and analyse the views of the various stakeholders concerning a proposal to establish a TMZ over the existing Walney Wind Farms and the Walney Extension Offshore Wind Farm in Morecambe Bay. Fundamentally, the aim of the consultation was to enable DONG Energy to obtain or confirm views and opinions about the impact of the proposed airspace change.

Consultees

The Consultation Document was circulated to a total of 72 consultee organisations or individuals; of these three emails were returned as undelivered. The aviation consultees included aviation parties such as the Ministry of Defence (MOD), airlines, aircraft operators, adjacent aerodromes, all local airspace users and the national bodies representing all UK aviation interests who may be affected by the regulatory requirements within the TMZ. National bodies such as LAA, BALPA, AOA etc. are represented through the auspices of the National Air Traffic Management Advisory Committee (NATMAC), sponsored by the CAA. A number of military organisations are also members of the NATMAC.

Non-aviation stakeholders for consultation included environmental and heritage organisations, local planning authorities and the general public. Although the proposed change to the airspace


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lies offshore, and there are no changes to the way aircraft operate over land, the neighbouring coastal districts and parish councils were also consulted. The views of individual members of the public were also welcomed.

Consultation Statistics

A total of ten responses (approximately 15 % of consultees) to the consultation were received, from a total of 69 consultees.

Of these, two consultees (20 %) supported the proposal to establish a TMZ over the Morecambe Bay Offshore Wind Farms; six consultees (60 %) provided a neutral response, whereby the consultee did not object or provided no comments on the proposal; and one consultee (10 %) objected to the proposal.

One consultee raised other comments relating to the presence of the Walney Extension Offshore Wind Farm and not to the development of the Walney TMZ. Such comments have therefore not been included in the analysis.

Next Stages of the ACP

The consultation process constitutes the third stage of the CAA’s overall process laid down in CAP 725 [Reference 1] leading to an Airspace Change Proposal.

DONG Energy will submit a formal Airspace Change Proposal to the Airspace Regulation (AR) of the CAA detailing the case for the proposed TMZ. It is a requirement of the consultation process that DONG Energy will provide the CAA with full details of the consultation (including copies of responses and correspondence) together with all documentation necessary for the promulgation of the proposed TMZ. Following receipt of the formal Airspace Change Proposal, the CAA then requires a 16-week period to conduct its own internal analysis of the final proposal and consultation results, before arriving at a Regulatory Decision.

Should the CAA, without the need for further design optimisation or analysis, accept the Airspace Change Proposal, DONG Energy suggest that the implementation of the TMZ would take place on a single date to coincide with the initial operational date of the Walney Extension Offshore Wind Farm, expected to be in mid-2017.

DONG Energy extend their thanks to all consultees and other individuals who took their time to participate in this consultation and for their very useful feedback.


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Contents

1 Glossary ......................................................................................................................................... 7

2 Introduction ............................................................................................................................... 11

2.1 General ......................................................................................................................................................... 11 2.2 Subject of the Consultation ................................................................................................................. 11 2.3 Development of the Consultee List .................................................................................................. 12 2.4 Confidentiality .......................................................................................................................................... 12 2.5 Document structure ............................................................................................................................... 13

3 Consultation Statistics ............................................................................................................ 14

3.1 Introduction .............................................................................................................................................. 14 3.2 Consultee Organisations....................................................................................................................... 14 3.3 Responses ................................................................................................................................................... 15 3.4 Meetings with Major Stakeholders .................................................................................................. 16

4 Analysis of Responses ............................................................................................................. 17

4.1 Introduction .............................................................................................................................................. 17 4.2 Response Support Ratio ....................................................................................................................... 17 4.3 Key Issues arising from Consultee Responses ............................................................................ 18 4.4 Objection ..................................................................................................................................................... 19 4.5 Isle of Man Airport PSR Concerns .................................................................................................... 19

5 Post-Consultation Actions ..................................................................................................... 20

5.1 Post-Consultation Review ................................................................................................................... 20 5.2 DONG Energy Conclusions .................................................................................................................. 20 5.3 Next Stages of the ACP .......................................................................................................................... 20

6 References .................................................................................................................................. 21

A1 Consultation Background and Methodology .................................................................. 22

A1.1 Background to the Consultation ........................................................................................................ 22 A1.2 Method of Consultation ......................................................................................................................... 22

A2 Stakeholder / Consultee List ................................................................................................ 24

A2.1 Aviation Consultees: Aerodromes / Local Aviation Consultees ........................................... 24 A2.2 Aviation Consultees: National Organisations (NATMAC) ....................................................... 24 A2.3 Non-Aviation Consultees: National Bodies ................................................................................... 26 A2.4 Non-Aviation Consultees: Regional Council Authorities ......................................................... 26 A2.5 Non-Aviation Consultees: Regional Council Authorities ......................................................... 27


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A2.6 Information Organisations: Members of Parliament ................................................................ 28 A2.7 Information Organisations: Civil Aviation Authority ................................................................ 28

A3 Key Issues arising from the Consultation ........................................................................ 29

Table of Figures

Figure 1 Distribution of Consultees ....................................................................................................................... 15 Figure 2 Responses from Listed Consultees ....................................................................................................... 16 Figure 3 Support Ratio from Listed Consultees ................................................................................................ 18

Table of Tables

Table 1 Responses from Consultees ...................................................................................................................... 15 Table 2 Pre-Consultation Stakeholder Meetings .............................................................................................. 16


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1 Glossary

Acronym Meaning

ACC Airport Consultative Committee

ACP Airspace Change Process

ACAS Airborne Collision Avoidance System

AEF Air Experience Flight

agl Above ground level

AIP Aeronautical Information Publication

AOA Airport Operators Association

AOPA Aircraft Owners and Pilots Association

AR Airspace Regulation

ARA Advisory Radio Area

ARPAS Association of Remotely Piloted Aircraft Systems

ASL Above Sea Level

ATC Air Traffic Control

ATM Air Traffic Management

ATSOCAS Air Traffic Service Outside Controlled Airspace

ATS Air Traffic Service

ATSU Air Traffic Service Unit

BAA British Airports Association

BABO British Association of Balloon Operators

BALPA British Airline Pilots’ Association

BATA British Air Transport Association

BBAC British Balloon and Airship Club


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BBGA British Business and General Aviation Association

BGA British Gliding Association

BHA British Helicopter Association

BHPA British Hand Gliding and Paragliding Association

BIA Blackpool International Airport

BMAA British Microlight Aircraft Association

BMFA British Model Flying Association

BPA British Parachute Association

CAA Civil Aviation Authority

CAP Civil Aviation Authority Aeronautical Publication

CAS Controlled Airspace

CAT Commercial Air Transport

CHA Chester Hawarden Airport

CTA Control Area (Class D UK Airspace)

DAATM Defence Airspace and Air Traffic Management

DAP Directorate of Airspace Policy (part of the CAA – now SARG)

DfT Department for Transport

DS Deconfliction Service

ELFAA European Low Fares Airline Association

FL Flight Level

GA General Aviation

GASCo General Aviation Safety Council

GAT General Air Traffic

GAPAN Guild of Air Pilots and Air Navigators

GATCO Guild of Air Traffic Control Officers

HCGB Helicopter Club of Great Britain


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HQ DAAvn Headquarters Director Army Aviation

HTZ Helicopter Traffic Zone

IAIP Integrated Aeronautical Information Package

IFP Instrument Flight Procedure

IoMA Isle of Man Airport

LAA Light Aircraft Association

LARS Lower Airspace Radar Service

LJLA Liverpool John Lennon Airport

LoA Letter of Agreement

MAA Military Aviation Authority

MOD Ministry of Defence

MP Member of Parliament

NATMAC National Air Traffic Management Advisory Committee

NATS The National Air Traffic Service Provider

NERL NATS En-Route Ltd

NCHQ Navy Command Head Quarters

NM Nautical Miles

OS Ordnance Survey

PINS Planning Inspectorate

PSR Primary Surveillance Radar

RAF Royal Air Force

SARG CAA Safety and Airspace Regulation Group

SRG Safety Regulation Group (part of the CAA)

SSR Secondary Surveillance Radar

TMZ Transponder (SSR) Mandatory Zone

UAS University Air Squadron


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UAV Unmanned Air Vehicles

UKAB UK Airprox Board

UKFSC UK Flight Safety Committee

VGS Volunteer Gliding Squadron

VOR VHF Omni Directional Radio Range; a type of short-range radio navigation system for aircraft

WAL Wallasey VOR

WoDS West of Duddon Sands

Walney Extension Offshore Wind Farm TMZ – Final Report on the Stakeholder Consultation | Introduction

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2 Introduction

This document is the Final Report of the consultation, carried out by DONG Energy between 10th October 2014 and 11th January 2015, on the establishment of a Transponder Mandatory Zone (TMZ) over the existing Walney (1 and 2) Offshore Wind Farms, the Walney Extension Offshore Wind Farm, West of Duddon Sands (WoDS), Ormonde and Barrow Wind Farms. The aim of this report is to present details on the statistical data arising from the responses to the consultation, together with an analysis of the feedback received.

2.1 General

DONG Energy is the Sponsor for a proposed airspace change over the existing Walney (1 and 2) Offshore Wind Farms, the Walney Extension Offshore Wind Farm, West of Duddon Sands (WoDS), Ormonde and Barrow Wind Farms to the northwest of Morecambe Bay in the Irish Sea.

As part of the Civil Aviation Authority’s (CAA) Airspace Change Process (ACP)(CAP 725) [Reference 1], DONG Energy is required to submit a case to the CAA to justify the establishment of a Transponder Mandatory Zone (TMZ) over the existing Walney, WoDS, Ormonde and Barrow Wind Farms and the Walney Extension Offshore Wind Farm, and to undertake a consultation exercise with all relevant stakeholders. This ensures that all stakeholders who may be affected directly or indirectly by the proposed change are consulted, as well as highlighting any environmental impacts that the proposed airspace change may have.

DONG Energy has engaged Osprey Consulting Services Ltd (Osprey) to project manage the ACP on their behalf. The Walney TMZ airspace change is hereafter referred to as ‘the proposal’.

This document is the Final Report on the consultation carried out by DONG Energy between 10th October 2014 and 11th January 2015. The background to the consultation and the methodology used are detailed in Annex A1 to this document. The aim of this report is to present details on the statistical data arising from the responses to the consultation, together with an analysis of the feedback received.

DONG Energy would like to thank all consultees and other individuals who took the time to participate in this consultation and for their very useful feedback.

2.2 Subject of the Consultation

The purpose of this consultation was to gather and analyse the views of the various stakeholders concerning a proposal to establish a TMZ over the existing Walney (1 and 2), the Walney Extension Offshore Wind Farm, WoDS, Ormonde and Barrow Wind Farms in Morecambe Bay. Fundamentally, the consultation will enable DONG Energy to obtain or confirm views and opinions about the impact of the proposed airspace change.


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The proposed establishment of the TMZ is one element of a three-part Mitigation Package aimed at negating the impact of the clutter from the Walney Extension Offshore Wind Farm wind turbines upon the Warton Primary Surveillance Radar (PSR). The three parts are:

Element 1: Establishment of a TMZ; Element 2: Authorisation to control Secondary Surveillance Radar (SSR)-only

and; Element 3: Suppression of PSR returns within the boundary of the Wind

Farms.

Such an airspace change is necessary in order to mitigate the effects of the wind turbines on the Warton PSR. This will ensure that a full suite of Air Traffic Service Outside Controlled Airspace (ATSOCAS)1 can continue to be provided, whilst maintaining the current levels of airspace effectiveness and efficiency in this area.

This consultation is not about facilitating change of routine air traffic procedures at local aerodromes.

2.3 Development of the Consultee List

A full list of consultees was developed with the advice of the CAA and is given at Annex A2.

At the start of the consultation, DONG Energy sent out a notification to 72 consultees, comprising:

39 Aviation “National Organisations” (CAA National Air Traffic Management Advisory Committee (NATMAC2) list);

12 Local Aerodromes/Aviation Consultees; 5 Members of Parliament (MP); 11 Council Wards; and 5 Local/National Environmental Organisations.

Of the above, three emails were returned as undelivered. Therefore, the total number of consultees that received the consultation email was 69.

Further detail on the categories of consultee organisations is provided in Section 3.2 of this report.

2.4 Confidentiality

The CAA Safety and Airspace Regulation Group (SARG) requires that all consultation material, including copies of responses from consultees and others, is included in any formal submission to the CAA of an Airspace Change Proposal.

1 ATSOCAS are provided by a variety of air traffic units and used by a wide variety of users from General Aviation to commercial flights and military aircraft. 2 It should be noted that NATMAC comprises a total of 39 organisations, represented by 45 individuals. The consultation document was circulated to each individual. However, this analysis reflects the views of the organisations as a whole and not of the individuals representing them. In some cases it was found that representation had changed from the list provided by the CAA.


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DONG Energy undertakes that, apart from the necessary submission of material to the CAA and essential use by Osprey for analytical purposes in developing this report and subsequent Airspace Change Proposal material, DONG Energy will not disclose personal details or content of responses or submissions to any third parties. Osprey and DONG Energy consultants are signatories to confidentiality agreements in this respect.

2.5 Document structure

This document contains eight main sections and three Annexes, outlined below for convenience:

Section 1 provides a glossary; Section 2, this section, introduces the document; Section 3 details the consultation statistics; Section 4 provides an overview of the responses and support ratio; Section 5 highlights the post-consultation actions; and Section 6 provides a list of references.

There are three Annexes:

Annex A1 details the background to this consultation and the consultation methodology;

Annex A2 lists the consultees; and Annex A3 highlights the key issues arising from the consultation responses.

Walney Extension Offshore Wind Farm TMZ – Final Report on the Stakeholder Consultation | Consultation Statistics

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3 Consultation Statistics

The Walney TMZ consultation invitations were circulated by email to a total of 72 stakeholder consultee organisations or individuals, of which three were returned as undeliverable. A total of ten responses to this consultation were received.

3.1 Introduction

This section describes the categories of consultee organisations and individuals that were consulted and gives a breakdown of the responses received to date.

3.2 Consultee Organisations

The Walney TMZ consultation invitations were circulated to a total of 72 stakeholder consultee organisations or individuals detailed in Annex A2.

As stated in Section 2.3, three consultation emails was returned as undelivered, making the total number of consultees equal to 69.

The consultation document was distributed via a dedicated link on the DONG Energy website3 and by email to all consultees.

Consultees broadly fall into two categories:

Aviation consultees; and Non-aviation consultees.

Aviation consultees included aviation parties such as MOD, airlines, aircraft operators, adjacent aerodromes, all local airspace users and the national bodies representing all UK aviation interests who may be affected by the regulatory requirements within the TMZ. National bodies such as LAA, BALPA, AOA etc. are represented through the auspices of the NATMAC, sponsored by the CAA. A number of military organisations are also members of the NATMAC.

Non-aviation stakeholders for consultation included environmental and heritage organisations, local planning authorities and the general public. The consultee groups that received the consultation email are detailed in Figure 1 below.

3 http://www.walneyextension.co.uk/en/application-for-consents/consultation-for-transponder-mandatory-zone.


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Figure 1 Distribution of Consultees

3.3 Responses

A total of ten responses (14.5 % of consultees) to this consultation were received. A breakdown of these is provided in Table 1 below.

Consultee Groups Number Consulted4

Responses %

1 NATMAC (Civil) 34 5 14.71

2 NATMAC (Military) 5 1 20.00

3 Local Aerodromes/Aviation Consultees 12 4 33.33

4 MPs 5 0 0

5 Council Wards & Local Authorities 9 0 0

6 National Bodies/Environmental Organisations 5 0 0

7 Individuals N/A 0 N/A

Totals 69 10 14.5 %

Table 1 Responses from Consultees

4 Includes only consultees who received the consultation email.


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Figure 2 Responses from Listed Consultees

It should be noted that “NATMAC (Civil)” and “NATMAC (Military)” comprise those organisations who are members of the CAA’s NATMAC. The NATMAC consultee list includes some CAA Departments who, for reasons of CAA impartiality, do not respond to consultations.

3.4 Meetings with Major Stakeholders

Prior to the commencement of the consultation period, a number of meetings were held with some of the major stakeholders. Although most of these organisations had been contacted during the initial requirements capture phase, the purpose of these meetings was to present the detail that would be incorporated into the Consultation Document to ensure there were no surprises for stakeholders when it came to formal comment.

Details of the pre-consultation meetings that were organised with the major stakeholders are given in Table 2 below.

Stakeholder Meeting Date Notes

BAE Barrow/Walney Island 10th July 2014 Submitted a letter response

Cumbria Airspace Users Forum

24th September 2014 Meeting minutes available

Bond Helicopters 15th August 2014

Table 2 Pre-Consultation Stakeholder Meetings

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4 Analysis of Responses

Of the ten responses received; two consultees supported the proposal; six consultees provided a neutral response, whereby the consultee did not object or provided no comments on the proposal and one consultee objected to the proposal. One consultee raised other comments relating to the presence of the Walney Extension Offshore Wind Farm and not to the development of the Walney TMZ.

4.1 Introduction

This section provides details on the number of responses received from the various organisations and individuals that were consulted. It also explores the support ratio of consultee responses received to give a general indication on the stakeholder acceptance of this proposal.

4.2 Response Support Ratio

As seen in Figure 3, of the ten responses received from the consultee organisations:

Two consultees (20 %) supported the proposal to establish a TMZ over the Morecambe Bay Offshore Wind Farms;

Six consultees (60 %) provided a neutral response, whereby the consultee did not object or provided no comments on the proposal;

One consultee (10 %) objected to the proposal; and One consultee (10 %) raised other comments relating to the presence of the

Walney Extension Offshore Wind Farm and not to the development of the Walney TMZ. Such comments have therefore not been included in the analysis.


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Figure 3 Support Ratio from Listed Consultees

4.3 Key Issues arising from Consultee Responses

The consultation process constitutes the fourth stage of the CAA’s seven-stage ACP (as defined in CAP 725 [Reference 1]). During Stage 1, a requirements capture workshop was organised at BAE Systems Warton. The purpose of this meeting was to undertake a detailed analysis of current operations in the area of the Walney Wind Farms and the challenges those operations face. The workshop further identified current issues and discussed potential airspace constructs that would meet those challenges. Stakeholder identification and management were also discussed.

This workshop was followed by a Framework Briefing with the CAA (Stage 3 of the ACP) to outline the proposed airspace change. Also, as stated in Section 3.4 of this document, prior to the commencement of the consultation period, a number of meetings were held with some of the major stakeholders. The purpose of these meetings was to present the detail that would be incorporated into the Consultation Document to ensure there were no surprises for stakeholders when it came to formal comment.

Consequently, by the time the consultation stage is reached there should have been few areas of contention, highlighted by the major stakeholders that had not previously been raised and addressed. The Consultation Document itself incorporated all the preliminary feedback received from the major aviation stakeholders.

The response analysis process identified just a single issue of concern. This is detailed in Annex A3, together with DONG Energy’s and Warton’s consideration of this concern.


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4.4 Objection

4.4.1 British Handgliding and Paragliding Association

The British Handgliding and Paragliding Association (BHPA) represents over 90% of some 7,000 hand glider, paraglider, powered hand glider and powered paragliders pilots flying in the UK. In response to the consultation, BHPA said that whilst it is extremely unlikely that any of their powered and unpowered pilots would be affected by the proposal, the BHPA object to the proposal because it fails to follow best practice. BHPA further pointed out that there are a number of aspects to the consultation that cause BHPA concern and would be of significantly higher importance should the same matters occur in a proposal for a TMZ in another location.

BHPA stated that the proposed TMZ is considerably larger than it needs to be and should only cover the turbines that cause an issue. BHPA further cast doubt on whether there is sufficient information within the proposal for consultees to be able to reach a meaningful decision with respect to whether the possible radar solutions have been appropriately assessed. BHPA believe that ANSPs should be getting their radar fixed, with it being paid for by the developer if necessary.

4.5 Isle of Man Airport PSR Concerns

Isle of Man Airport (IoMA) expressed their concerns regarding technical omissions to the consultation document and technical effects on the IoMA Primary Surveillance Radar by offshore wind farms.

The issues raised above relate specifically to the presence of the Walney Extension Offshore Wind Farm and not to the proposed TMZ. Following a positive Secretary of State decision on 7th November, on a ‘consent’ for the Walney Extension Offshore Wind Farm, these issues have therefore not been included in this TMZ consultation analysis.

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5 Post-Consultation Actions

No new or unexpected issues have arisen which would affect DONG Energy’s proposal to introduce a TMZ over the Morecambe Bay Offshore Wind Farms. DONG Energy will submit a formal Airspace Change Proposal to the Airspace Regulation (AR) of the CAA detailing the case for the proposed TMZ.

5.1 Post-Consultation Review

All responses received throughout the consultation period have been subjected to a detailed review and analysis by DONG Energy, in order to identify emerging issues of concern.

5.2 DONG Energy Conclusions

Based on the comments received, DONG Energy has concluded that no new or unexpected issues have arisen which would affect DONG Energy’s proposal to introduce a TMZ over the Morecambe Bay Offshore Wind Farms.

5.3 Next Stages of the ACP

The consultation process constitutes the third stage of the CAA’s overall process laid down in CAP 725 [Reference 1] leading to an Airspace Change Proposal.

DONG Energy will submit a formal Airspace Change Proposal to the Airspace Regulation (AR) of the CAA detailing the case for the proposed TMZ. It is a requirement of the consultation process that DONG Energy will provide the CAA with full details of the consultation (including copies of responses and correspondence) together with all documentation necessary for the promulgation of the proposed TMZ.

Following receipt of the formal Airspace Change Proposal, the CAA then requires a 16-week period to conduct its own internal analysis of the final proposal and consultation results, before arriving at a Regulatory Decision. Should the CAA, without the need for further design optimisation or analysis, accept the Airspace Change Proposal, DONG Energy suggest that the implementation of the TMZ would take place on a single date to coincide with the initial operational date of the Walney Extension Offshore Wind Farm, expected to be in mid-2017.

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6 References

Reference Name Origin

1 CAP 725 CAA Guidance on the Application of the Airspace Change Process

Third Edition (corrected) April 2007

CAA

ISBN 978 0 11790 739 3

2 Code of Practice on Consultation

July 2008

Cabinet Office

URN 08/1097

Table 1 Table of References

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A1 Consultation Background and Methodology

A1.1 Background to the Consultation

DONG Energy wishes to develop an extension to the existing operational Walney Offshore Wind Farms (1 and 2), located northwest of Morecambe Bay in the Irish Sea.

The presence of the Walney Extension turbines would affect BAE Systems Warton (Warton) Aerodrome flying and Air Traffic Service (ATS) operations and potentially those of BAE Systems at Barrow/Walney Island Aerodrome, with the most significant effect being the detection of the Walney Extension wind turbines by the Warton Primary Surveillance Radar (PSR). DONG Energy is working with Warton to identify a mitigation to the effect of the turbines on the PSR which will enable the Walney Extension wind turbines to be built without affecting Warton flying operations. Warton’s preferred solution is to establish a TMZ around the Walney, WoDS, Ormonde and Barrow operational Wind Farms and Walney Extension (collectively referred to as the Morecambe Bay Offshore Wind Farms) up to Flight Level (FL)100, (10,000 ft) to be active during the Warton Lower Airspace Radar Service (LARS) provision times.

DONG Energy, as the sponsor of the proposed airspace change, is required to submit a case to the Civil Aviation Authority (CAA) to justify the change in airspace over the Morecambe Bay Offshore Wind Farms. Also, as part of the CAA’s Airspace Change Process (ACP), it is DONG Energy’s responsibility to consult with all relevant stakeholders who may be directly or indirectly affected by the proposal.

A1.2 Method of Consultation

The Walney TMZ consultation was conducted in accordance with the principles set out in the Cabinet Office Code of Practice on Consultation [Reference 2], as required by the CAA.

A comprehensive Consultation Document was prepared by DONG Energy, with the assistance of Osprey. Full details of the proposed change, including rationale, perceived impacts and the mitigation measures undertaken by DONG Energy, were provided in the Consultation Document.

A link to the Consultation Document was made available on the DONG Energy website5. All consultees were notified by email detailing the consultation and how to access the Consultation Document.

Local aviation stakeholders were engaged at an early stage during the design process. Prior to the preparation of the Consultation Document, meetings were conducted with the following major stakeholders:

5 http://www.walneyextension.co.uk/en/application-for-consents/consultation-for-transponder-mandatory-zone

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Blackpool International Airport (BIA)

BAE Barrow/Walney Island;

Cumbria Airspace Users Forum; and

Bond Helicopters.

The primary purpose of these meetings was to present the detail that will be incorporated into the Consultation Document to ensure there are no surprises for stakeholders when it comes to formal comment.

Full consultation commenced with wide circulation of the electronic Consultation Document to all identified stakeholders on 10th October 2014 on completion of the design process and environmental studies. The consultation process ran until 11th January 2015 - a period of fourteen weeks. This allowed a minimum of twelve weeks required for formal consultation6, recognised the number of Public Holidays during the period and provided scope for any unforeseen delays at the start, or any significant issues that may arise during the process.

Consultees were asked to consider the proposal and submit a response to DONG Energy using a response form on the DONG Energy consultation website or through a dedicated email address ([email protected]).

In order to promote maximum response, three reminder emails were sent to those consultees who had not yet provided a response to date. The first reminder was sent on 20th November 2014 (more than one month before the end of the consultation period) and a second reminder email on 22nd December 2014, to those consultees who had not yet responded to date. A third email reminder was sent to only the aviation stakeholders (NATMAC) who had not yet responded to date.

6 The Cabinet Office Code of Practice on Consultation [Reference 2] and the CAA requirements specify a minimum period of 12 weeks for consultation.

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A2 Stakeholder / Consultee List

A2.1 Aviation Consultees: Aerodromes / Local Aviation Consultees

Consultee Also known As

Blackpool International Airport EGNH

Bond Offshore Helicopters

Caernarfon Aerodrome Bangor

Chester Hawarden EGNR

City (Barton) Heliport Manchester

EGCB

Ince West Lancashire Microlight

Isle of Man Airport EGNS

Liverpool John Lennon Airport EGGP

Lleweni Parc Airfield Denbigh Gliding

RAF Woodvale EGOW

Barrow/Walney Island EGNL

Lakes Gliding Club

A2.2 Aviation Consultees: National Organisations (NATMAC)


Aircraft Owners and Pilots Association AOPA UK

Airport Operators Association AOA

Association of Remotely Piloted Aircraft Systems ARPAS

Aviation Division Navy Command Headquarters NCHQ

Aviation Environment Federation AEF

BAESystems Warton BAES


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British Air Transport Association BATA

British Airline Pilots’ Association BALPA

British Airways BA

British Association of Balloon Operators BABO

British Balloon and Airship Club BBAC

British Business and General Aviation Association BBGA

British Gliding Association BGA

British Hang Gliding and Paragliding Association BHPA

British Helicopter Association BHA

British Microlight Aircraft Association BMAA

British Model Flying Association BMFA

British Parachute Association BPA

Civil Aviation Authority CAA SRG

Defence Airspace and Air Traffic Management (incl. the Military User Advisory Consultative Team)

DAATM (MUACT)

Euro UAV Systems Centre Ltd

European Low Fares Airline Association ELFAA

General Aviation Safety Council GASCo

Guild of Air Pilots and Air Navigators GAPAN

Guild of Air Traffic Control Officers GATCO

Headquarters Director Army Aviation HQ DAAvn

Heavy Airlines

Helicopter Club of Great Britain HCGB

Light Aircraft Association LAA

Light Airlines

Low Fares Airlines

Military Aviation Authority MAA


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Ministry of Defence MOD

MOD Flight Test Regulator

NATS (NSL) NSL

NATS En-Route Ltd NERL

PPL/IR Europe PPL/IR

RAF Safeguarding Team RAF ST

The British Business and General Aviation Association BBGA

UK Airprox Board UKAB

UK Flight Safety Committee UKFSC

3 AF-UK/A3

A2.3 Non-Aviation Consultees: National Bodies

Consultee

National Trust for England

English Natural Heritage

Friends of the Earth

Campaign to Protect Rural England

Natural England

A2.4 Non-Aviation Consultees: Regional Council Authorities

Consultee

Barrow-In-Furness Council

Copeland Borough Council

Fleetwood Town Council

Lancaster City Council

South Lakeland Council


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A2.5 Non-Aviation Consultees: Regional Council Authorities

Borough of Barrow-In-Furness

Consultee

Askam and Ireleth Parish Council

Walney North Ward

Walney South Ward

Roosecote Ward

Copeland Borough Council

Consultee

Haverigg Ward

Millom

Fleetwood Town Council

Consultee

Pharos Parish

Warren Parish

Rossall Parish

Lancaster City Council

Consultee

Bolton-Le-Sands

Carnforth Ward

Harbour Ward

Heysham North

Heysham Central

Heysham South


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South Lakeland District Council

Consultee

Arnside and Beetham

Grange North

Grange South

Ulverston East

Ulverston South

A2.6 Information Organisations: Members of Parliament

UK Parliament

Consultee Constituency

John Woodcock MP Barrow and Furness

Jamie Reed MP Copeland

Eric Ollerenshaw MP Lancaster and Fleetwood

David Morris MP Morecambe and Lunesdale

Tim Farron MP Westmorland and Lonsdale

A2.7 Information Organisations: Civil Aviation Authority


Safety and Airspace Regulation Group SARG

Safety and Airspace Regulation Group Head of Aerodrome & Air Traffic Standards Division

SARG AAA Manager Aerodromes

Safety and Airspace Regulation Group Flight Ops Division

SARG Flight Ops Division

Safety and Airspace Regulation Head of Airspace Regulation

SARG AAA Manager Airspace Regulation

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A3 Key Issues arising from the Consultation

Issue Specimen Comment DONG Energy/Warton

Comment

1 Impact on

handgliders and

paragliders

The matters of concern are:

1. Page 14, “The existing operational

Walney 1 and 2, Ormonde and Barrow

Wind Farms do not affect the Warton PSR,

as the wind turbines are smaller than

those planned for the extension. However,

whilst the existing operational turbines do

not affect the Warton PSR, from an

airspace user’s visual perspective DONG

Energy and Warton consider that if

mitigation involves a change to local

airspace arrangements, then it is simpler

to encompass all wind turbines in the

immediate area. It would be difficult for a

pilot to make a visual distinction between

the existing Morecambe Bay Offshore

Wind Farm turbines and those of the

planned Walney Extension.”

This means that because producers of the

proposal doubt the abilities of pilots to

navigate (with no evidence to support this

assertion) the TMZ is considerably larger

than it needs to be. Following the airspace

principles from the CAA the TMZ should

only cover those turbines that cause an

issue.

2. Paragraph 6.3.1, “It is not possible

to remove only the radar returns from the

wind turbines without also removing

‘wanted’ radar returns from aircraft. This

is why PSR Blanking in isolation is not

considered a viable mitigation for the

Walney Extension.”

The following links would appear to show

The concern regarding the size of

the consulted TMZ is noted but

not supported by evidence from

individuals within the project

who have flown over the

Morecambe Bay Offshore Wind

Farms during various VMC. On

many occasions of varying

visibility, natural lighting and

direction of travel the extent and

boundaries of the subject Wind

Farms can be indistinguishable.

Your concern regarding technical

solutions to mitigate the effects

of wind turbine generated

‘clutter’ on a PSR is

acknowledged, it is recognised

that there are a number of

‘radar’ solutions being

developed, and have been

demonstrated, by various

manufacturers. These solutions

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this to be inaccurate:

http://helihub.com/2014/10/20/new-

airport-radar-to-mitigate-impact-of-wind-

turbines/

http://www.aveillant.com/news/problem-

radar-isnt-wind-farms-its-radar/

3. There is insufficient information

within the proposal for consultees to be

able to reach a meaningful decision with

respect to whether the possible radar

solutions have been appropriately

assessed. It could be that the TMZ is the

cheapest option so radar remediation was

written up as technically too difficult in

order to maximise profit. We believe that

ANSPs should be getting their radar fixed,

with it being paid for by the developer if

necessary.

are being closely scrutinized as

part of the UK Government’s

commitment to offshore

renewable energy recovery and

its renewable targets. Due to the

large number of wind turbines

planned for the Walney Offshore

Extension Wind Farm, and other

turbines existing within its close

proximity, simple radar

modifications to provide

mitigation are not possible with

the existing technology.

It is BAES Warton’s view that

PSR solutions are not yet fully

developed. Furthermore, these

PSR solutions to not yet fully

address system and aerodrome

environment intergation and

would currently occasion

unacceptable technical risk to

BAES and Warton’s operations.

This is not to say that an

acceptable technical mitigation,

meeting CAA and MoD approval,

will not be available, and

acceptable to Warton, in the

future which would thence

demand the subsequent removal

of the TMZ.

Documents

Walney Extension Offshore Wind Farm TMZ Final Report on the Stakeholder Consultation · 2017-03-23 · Walney Extension Offshore Wind Farm TMZ – Final Report on the Stakeholder