Dear BHPA Club Chief Coach, Club Secretary* or School CFI
Airspace Consultation - Moray Firth Airspace Change Proposal (ACP)
https://airspacechange.caa.co.uk/PublicProposalArea?pID=750
I am emailing you as contact for a BHPA club or school. I attach a link concerning an airspace change proposal. The BHPA sites database records the club or school as being located where its operations may possibly be affected by this proposed airspace change.
The scope of the proposal has not been evaluated to see if it will affect BHPA school / club flying activities. I have been instructed to forward this proposal to clubs and schools that may be affected, so they can review and engage directly with the ACP sponsor.
Please refer to the information on the link provided for information on the ACP. If no further details are provided, you may wish to register your interest by using the “contact” link on the CAA’s Airspace Change Proposal portal.
If your club wishes to comment directly on the airspace change proposal, please copy the BHPA Office into Club responses for the purpose of record keeping (off...@bhpa.co.uk).
Collaboration with other BHPA clubs and representatives of other types of soaring aircraft (BGA) is very worthwhile. This was demonstrated to good effect with the Regional Soaring Airspace Group, formed to respond to a specific ACP in Yorkshire (the ACP was subsequently rejected by CAA). A document on the group’s experience, and their recommendations to other BHPA clubs is available from me. This is useful background information which may inform your method of approach to the ACP.
The General Aviation Alliance (GAA) of which the BHPA is a part, may well respond to the airspace change proposal on behalf of general aviation (GA) activities, although this has not been confirmed at this stage. If the airspace change proposal potentially affects several BHPA clubs, it is helpful if the clubs appoint between them a member as a “regional airspace lead” person who acts as an inter-club liaison. If you let me know who is nominated, I can forward this person’s contact details on to other GAA member organisations who may wish to tie-in.
Points to consider if you raise an objection to an ACP:
1) The numbers, the extent of our activities may not be fully appreciated. The limitations on EC equipage for our aircraft may be unknown or misunderstood. The data on the BHPA’s Electronic Conspicuity Position Paper may be useful here – extract the relevant data in support of your response, or provide a link to the Paper. The Paper can be found here: https://www.bhpa.co.uk/documents/index.php?doc=BHPA_EC_Position.pdf
2) Safety. Whilst the proposal is designed to enhance safety within CAS, it may not have considered the safety of those operating aircraft outside it. They should consider any choke points (horizontal and vertical). Whist incursions into CAS are very rare, more CAS increases the likelihood of an inadvertent incursion. This needs to be treated with careful consideration as it could illustrate that we make mistakes, which in turn may be seen to imply incompetence.
3) The counter to the above is that we limit our flying activity. This would be an infringement of our civil liberties; something that goes against the general trend of encouraging people to make use of the great outdoors, both for physical and mental well-being.
4) Administration. If you cite examples of where the proposer hasn't considered something (e.g. safety outside controlled airspace) or has failed to follow the correct process (consultation) then this can be presented to the CAA as grounds to reject the proposal.
* This email has been sent only to the club contact listed on the directory of BHPA clubs and schools pages on the BHPA website, and to no other officers or coaches in your club. Please forward it to the relevant club committee member to ensure it is circulated appropriately within your club.
Kind regards