The new year has started with a flurry of airspace change proposals for drone operations and, with a segregate rather than integrate approach, it looks like General Aviation risks being excluded…
Words: Dave Calderwood
20 January 2021
Just over a month ago, the weekly FLYER Livestream talked about fantasy airspace changes. Just a bit of nonsense, of course, particularly one of the ideas put forward of a round-Britain coastal flightpath from the surface to 500ft. Of course we, and viewers commenting during the show, were having a laugh, but one comment stuck in my mind.
It was from Pete Stratten, CEO of British Gliding, who’s highly active in watching and acting upon airspace change proposals. Pete wrote: “Do it while we can, Dave – it’ll be the drone’s domain soon enough!”
“The obvious next question is why not fly at night, when there’s little or no GA around?”
Pessimistic, I thought at the time, but just a few weeks later and we’re looking at three Airspace Change Proposals – Oban-Mull-Coll, Goodwood and Land’s End-Scilly Isles and there may be more about to surface – where drone companies want to run trials that will affect both General Aviation and Commercial Aviation. Trials at the moment, but clearly there’s a desire to establish commercial operations using Small Unmanned Aircraft (SUA), to give drones one of their official names.
On one level it’s hard to argue against the trials. In the case of Skyports’ application to run trials in the spring around the Scottish west coast islands of Mull, Tiree and Coll and back to the mainland at Oban, it’s at the request of NHS Scotland and is being funded through a joint initiative by the European and UK Space Agencies for the utilisation of space-enabled technology.
Skyports wants to fly Covid testing kits, samples and PPE to and from doctors’ surgeries on the islands. In the case of samples, whether that’s swabs or blood, there’s a potential huge saving in time which could impact on the patients’ health. We’re talking a matter of hours to take a sample from patient to laboratory analysis by drone instead of up to four days by sea and land. Who can argue against that?
Under current regulations, to run these trials the drone companies have to go through the whole airspace change process to establish Temporary Danger Areas (TDAs) – effectively, protected air ‘corridors’ that exclude other forms of aviation when active. This is the issue, at the moment: the drones have to have their own dedicated airspace rather than fitting in with the rest of aviation.
And this is at the heart of a proposal by a drone company called Skyports, which is seeking to establish a network of air corridors between several of Scotland’s west coast islands and the mainland. The TDAs will operate from the surface to various heights up to 950ft amsl – well above the normal 400ft max altitude for drones – and be activated by Notam when required.
A consultation, or ‘aviation stakeholder engagement exercise’, of just two weeks started on 11 January 2021 – although it was extended to 31 January just a week later. Why is it that short?
Skyports’ document says: “We acknowledge this is significantly less than the standard 12-week engagement and 4-6-week shorter engagement as per CAA DA/TDA policy 20200721. However, Skyports believes a shorter engagement period is sufficiently proportionate to the size of the change, the already completed engagements with local stakeholders during 2020 and the urgent imperative to support the NHS in Scotland Covid-19 response.”
Simon Whalley is Head of Regulation at Skyports. He told FLYER, “We’ve had a direct request from the NHS to help with our delivery drones moving Covid-19 samples, testing kits and PPE. At the same time it enables us to better understand how we can help the NHS but also integrate ourselves into their supply chain.
“The reason we have to fly over 400ft in some places, but not all – wherever possible we would always fly at 400ft to remain within the standard maximum altitude for drones – is principally because of the terrain. 400ft is mainly designed for drone operators that are operating within visual line of sight, but when you are operating beyond visual line-of-sight (BVLOS), particularly in an area where the terrain is quite undulating, it’s safer to be able to clear that at a slightly higher altitude.
“While the upper limits of the TDAs are expressed in amsl (above mean sea level), the unmanned aircraft will not be operated above 400ft agl (above ground level). Nevertheless, we are already looking to amend the routes based on the feedback we’ve received, which has the potential to reduce the altitudes of some TDAs and we will share amended proposals with stakeholders.”
The obvious next question is why not fly at night, when there’s little or no GA around?
“To operate at night in BVLOS needs an exemption,” said Simon. “We can do VLOS at night but we can’t do BVLOS at night without that specific approval. In some ways we will be operating at night, especially during the first phase because the hours of daylight are not so great at the beginning of the year, so we are applying to be able to operate outside of daylight hours.
“We will only be operating with two unmanned aircraft at any one time. During these flights, TDAs enabling other routes not being flown will not be activated. We will therefore deactivate TDAs outside of notified hours.
“We only want to operate in segregated airspace for the minimum amount of time necessary to meet the demands of the NHS; indeed not all medical facilities within the network. We are exploring with the CAA whether we can shorten the notice of activations which will have the potential for us to shorten the period of activations.
“The main thing is the response to the NHS. The purpose of this (trial) is not to be flying back and forth all the time, it’s providing a service when the NHS needs it. So, if they only need something delivered over one section of the route a couple of times a day, then that’s all we would do. If they needed that at 6pm, hopefully we would be able to do that. If they didn’t want anything along a certain route on a day then we wouldn’t operate that time – and we wouldn’t activate the TDA until we absolutely needed it.”
“Just as Skyports’ trial is set to get going on 8 April, so will the spring/summer season of GA flying to the islands”
However, that’s all very well, but just as Skyports’ trial is set to get going on 8 April, so will the spring/summer season of GA flying to the islands on the west coast of Scotland. An airfield that’s at the heart of the proposed network of TDAs is Glenforsa, on the Isle of Mull – and the airfield would simply not be able to operate should a SFC-450ft TDA sitting right over it was activated.
Think about this. Not only would pilots planning to fly in and out have to avoid the closed airspace – and we’ve already been told that it will be during daylight hours, for up to a half-day at a time, but also pilots routing through the area would not be able to plan it as an emergency or reserve airfield, or be able to land for lunch or anything, legally. Remember also that this part of Scotland is rightly renowned for its spectacular mountains and coastline – which, though beautiful, don’t make for good places to put down in an emergency or even just for bad weather.
Operator of the strip and hotel at Glenforsa is Brendan Walsh. He’s already had discussions with Skyports, pointing out that the TDAs will affect pilots flying into and out of Glenforsa – and at a time of year which gets busy because of the improving weather and daylight hours.
Simon’s response: “First, we have the airspace change consultation window open and we’re very keen to hear everyone’s views, suggestions, criticisms, anything. We want as much engagement as possible. If there are any problems or concerns we’re keen to allay them. If there are any issues we can resolve we’d definitely like to work with them (operators).
“We know there are some concerns about approach and departure into Glenforsa, an incredibly popular airfield and we understand why, it’s in a beautiful location. If we can shift the routes in such a way that would limit the impact or enable safer approaches and departure for GA aircraft then we’ll certainly do that. If there are times, in the interests of aviation safety, to not operate on a particular section then we’re open to that. Safety comes first.”
Brendan has also been told that Skyports may ‘share our intended operation location (route) directly with you the day before we are due to operate’, which, not surprisingly, isn’t terribly reassuring given that Brendan’s business and others on Mull and nearby islands will be forced to shut down during the busiest time of year.
Other operators are similarly affected – and some, such as Hamish Mitchell of Scotia Seaplanes (see sidebar) are incensed. One of Hamish’s points is that he, and some other operators including local flying clubs, have only found out about the consultation via the back door. Skyports position in that it has engaged with local aviation stakeholders seems flawed.
We asked Skyports which has been contacted as part of the engagement exercise. It said, “All of our airspace change proposals have been included on the CAA airspace change portal, where anyone can see the details, monitor the status and receive updates on any proposal listed by change sponsors.
“We have been in contact with a variety of local stakeholders, including aerodromes, airfields, flying clubs, air operators, air service providers, emergency services and representative bodies and alliances to name a few.
“If any additional names or organisations we should be speaking to are recommended to us then we will reach out to them with the details of our proposals so that they can provide their views.
“We are very keen to exploring other ways of reaching relevant aviation stakeholders about future developments at Skyports that might affect them, especially where doing so would improve the levels of engagement. We’d welcome the opportunity to appear in FLYER magazine and other publications and communications.”
Perhaps we should say here that our contact with Skyports was initiated by us, and while they were quick to respond, perhaps they need a wider outlook.
So while drone operators are locked into going the TDA route for now, that’s not a viable long-term solution. What is?
“We have to get into a position of getting drones to be able to operate either in completely non-segregated airspace along with manned aviation, safely integrated, communicating to each other, or some other form of airspace construct that enables everyone to be communicating,” said Simon.
“Until we get something like that – and the path towards that is not totally clear – permanent operations are unlikely to take place on any kind of scale.
“I think we’re getting there. Everyone has an interest in moving away from TDAs – they enable things but also block things. I think the CAA wants it, the drone industry wants it and manned aviation certainly wants it. It’s trying to work out what one or multiple solutions that will enable us to get there.”
Oban-Mull-Coll TDA
Goodwood TDA
Land’s End LETC
Land’s End TDA
CAA Airspace Change Portal
Last September, the Aviation Innovation Centre opened at Goodwood Aerodrome with the aim of ‘providing the UAV industry with a solution to develop, test, trial and showcase emerging technologies’.
“It’s the first of its kind in the UK, coming at a time when the aviation industry is focusing heavily on the development of commercial unmanned technology and with the UK CAA seeing a significant increase in UAV operation approval requests.”
This year will see a major trial by a consortium consisting of Trax International, uAvionix, Plane Finder and ANRA Technologies working with the Aviation Innovation Centre and Skyports to prove a concept of safe Beyond Visual Line of Sights (BVLOS) Unmanned Aerial System (UAS) operations alongside conventional traffic in non-segregated airspace.
“The consortium wishes to demonstrate the concept via a live airspace trial which needs the permission of the CAA,” says the trial strategy document. “However, before a live airspace trial can take place the consortium requires the protection of a Temporary Danger Area (TDA) to develop the operating procedures and protocols and gain the safety assurances needed to enable the CAA to permit such a trial.”
This was meant to happen last year (2020), however the pandemic got in the way and the TDA was never activated. Now it’s back with a request for a TDA going to the CAA at the end of January, with the intention of having the TDA in place from 11 April for five months.
The first thing pilots will notice is that the area around Goodwood will become a Transponder Mandatory Zone (TMZ) requiring aircraft to have Mode S or CAP1931 approved ADS-B Out devices. FLARM devices alone do not meet the requirements.
A local operator’s view – Hamish Mitchell operates Scotia Seaplanes, a Seaplane Training DTO based on the west coast of Scotland.
I discovered this ACP by chance – neither myself, nor two flying clubs based at Oban were notified as Stakeholders by the London-based sponsor. Indeed, I work as an ATCO covering the entire Scottish FIR. I consider myself to be pro-active and informed, yet was blindsided to learn there had been two drone trials in 2020.
These previous consultations were carried out during lockdown when no one was flying – literally and physically, below everyone’s radar, yet the sponsor claims they ‘developed a comprehensive picture of airspace usage in that area’. To then claim they ‘… do not wish to overburden stakeholders with an informal engagement exercise’, is both insolent and patronising.
We fly from Prestwick, Oban and Mull, providing a variety of training and have operated here since 2008. Our clients come from all around the world to learn and improve their skills in the magnificent Scottish landscape – private, commercial and military aviators, normally flying Boeings, SAABs, Pipers or even F16s.
In a normal season (April to October) we fly around 150 hours, a majority at low level in and around the Oban, Mull, Iona and Crinan area. We use Glenforsa and Oban frequently for both fuel and overnight stays, generating thousands of pounds for the local economy – and 2021 already looks busy, with significant pent-up demand, starting in April.
Under normal circumstances, Mull is a go-to destination for GA from right across the UK and beyond, and the coastal route from Lochgilphead is frequently used as a safe low-level route when cloud covers the mountains. Military low-flying within LFA14 is frequent and fast. This is the reality for those of us who live here, who operate here and who understand flying in Scotland.
This proposal imposes TDAs across a huge area, and gives me great cause for alarm – not only for the safety of my aircraft and clients, but also the potential future restriction of GA in general. GA by its very nature is flexible and cannot be predicted 24 hours in advance, and neither should it be. We operate tactically, responding to wind, weather, sea-state and fuel conditions on the day. That is the freedom afforded by Class G airspace and Scotland in particular – a freedom we should fight to defend.
The RAF teaches ‘Flexibility is the key to air power’ – the CAA’s principle for drones and flexible airspace use is one of integration with existing operations, not disproportionate, inflexible and discriminatory segregation by use of TDAs.
We’ve all seen how driverless cars are being developed around the world and it is not considered acceptable to force everyone off the road to make way for them – they would be expected to have effective anti-collision systems in place – and so it should be with UAVs.
It is also disingenuous to use the Trojan Horse of Covid as a lever to accelerate and bypass a proper and fulsome consultation. Many GA operators offered their services to fly time-critical supplies and samples last year and remain ready to help – how many were actually called and activated is quite another matter.
There are too many unanswered questions to feel comfortable about meekly nodding this through, this is the thin end of the wedge for GA, as exemplified by previous (barely publicised) trials.
How would any TDA operate in practice? How frequent and when? How do you access? Why block a 2km wide corridor up to 950ft in some places, when drones can fly at 100-150ft within 2-3m of accuracy?
A simple Notam’d track, clearly displayed on SkyDemon (like Red Arrows transits) is more practical. What are the wind and weather limits? What are the liabilities and procedures in case of a mid-air collision or crash with hazardous cargo? Hitting an 18kg drone (twice the weight of a Sea Eagle) at 140kt closing speed will not end well. Remember, we are carrying humans – drones have microchips and sample bottles. What happens during signal loss when military exercises jam GPS on the west coast? If drones have ADS-B In/Out, what are they actually doing with the ‘IN’ part?
The concept of carrying goods by drone is already proven, does it need to be proved again? The real challenge is to integrate – which ACPs like this avoid addressing. Why not fly at night with minimal GA around? A real-time webpage could show live drone location (like FlightRadar24) – not everyone has electronic conspicuity in the cockpit, but everyone has a mobile. If drone sponsors invested in 4G/5G coverage and ADS-B ground relays, you provide infrastructure and flexibility benefitting everyone.
We all recognise that UAV services and operatives are here to stay, politics will see to that. The community will embrace them, but only if they are safe, respectful and not restrictive toward existing airspace users. This proposal in its current form fails that test.
Whether you like it or not, unmanned aerial systems, drones or whatever else you want to call them are on their way. The challenge is how we’re going to integrate them into airspace that’s shared by all sorts of other users, including General Aviation.
If the spate of Airspace Change Proposals (ACPs) around Temporary Danger Areas (TDAs) are anything to go by, we need to figure how we’re going to integrate rather than segregate sooner rather than later. Although we’re going to have to work together, it seems we’re not off to a great start.
ACP sponsor Skyports may have stated that it wants to engage with the GA community but it somehow missed some pretty big parts of that local community right under their noses. Skyport also published news of a CAA announcement on UAS geozones that would require mandatory electronic conspicuity (EC). Wait, what, no, I can’t find that CAA announcement anywhere either.
Then there’s the CAA’s new and shiny CAP1616 process for handling ACPs. Step 3B says ‘Approve consultation’ when what that really seems to mean is ‘Approve consultation if we think it is big enough or important enough, but we’ll make that judgement based on unpublished criteria’.
And if you’re sitting there feeling rightly annoyed at what might be a sign of things to come, we have to hold our collective hands up and recognise that some (hopefully small) elements of the GA community are a long way from holding the high ground with threats, idle or otherwise, of damaging or jamming drones.
The early divisions don’t have to grow into fully blown trench warfare with the CAA running around in ‘no man’s land’ asking people if they fancy a game of football. We can work together. We just need less bullshit; more honesty, more transparency, better communication and more pragmatism. Right, who fancies a (virtual) round-table discussion?
Is it a coincidence or what? Land’s End Airport is involved in two separate airspace proposals.
One affects the existing Land’s End Transit Corridor (LETC), which serves commercial manned aircraft operations between the Scilly Isles and the mainland, including Skybus, the regular shuttle service.
The other is in the early stages of ‘proving the need’ for a Temporary Danger Area (TDA) connecting Land’s End Airport with the Isles of Scilly for unmanned cargo operations.
LETC first. The Airport says this is all about increasing safety of existing services, both fixed-wing (Twin Otters and Islanders) and helicopters. In 2019 there were more than 15,000 flights throughout the year and all the signs were that 2020 would have been higher until the pandemic came along. “We are forecasting a rapid return to pre-Covid traffic levels and then a continuation in the growth of air transport movements,” says the Airport’s Airspace Change Proposal.
“In recent years we have concluded and evidenced that there are aircraft flying within the LETC that are not in contact with an air traffic control unit. The nature of the airspace, Class G uncontrolled, means that pilots do not need to be in contact with ATC but because of the vast number of air traffic movements in the LETC, not being in contact with ATC is not the safest course of action to take.”
Land’s End Airport wants to make the existing air corridor into a Radio and Transponder Mandatory Zone (RMZ/TMZ) and widen it slightly to include the Instrument Approaches at either end. That’s because that south-west tip of the UK can get some pretty stormy weather and poor visibility at times.
The drone TDA trial aims to:
■ Demonstrate that a viable commercial operation is possible
■ Show that UAS flights will provide an alternative affordable method of transport for freight
■ Ultimately provide a service that can be safely conducted alongside existing manned services
■ Gather real data to support a safety case for permanent operations and ultimately create investment and jobs in Cornwall.
Steve Slater, CEO of the Light Aircraft Association (LAA), has already responded to the proposals. He said, “A significant amount of traffic travels from other airfields in the UK and the Isle of Scilly each year, as well as other flights routing around the south-west coast of Cornwall. There, aircraft are often equipped to a minimal level and not only have no transponders, but have no electrical systems to support them, and use handheld radios. This ACP would significantly impact these operations.
“In addition, this ACP states that the TDAs will be serviced by Scilly Isles and Newquay ATC units. Based on operational experience we have significant concerns whether Newquay has the radio range to cover lower level traffic crossing TDAs B, C and D. What are the proposed mitigations for this? We remain concerned that this will create longer-term precedents for future use of this airspace.”
Want to add your voice to the discussion? Join in on the FLYER forum.
Click image below for link.
