The Benbecula community is familiar with the term “remote control”. The QinetiQ Hebrides range on the Uists and Benbecula once considered a proposal to remotely control the firing range from a centre in Wales. We know that that option was not taken up and that local staff from QinetiQ were involved in making that decision.
We are particularly concerned with HIAL’s remote air traffic control proposal regarding downgrading of the ATC services at Benbecula and Wick airports to aerodrome flight information services. HIAL has stated that a flight information service is the norm for such airports, based on traffic levels. However, we see no reference to a safety case for the proposals in published board minutes. We note that the Scottish Government is silent regarding HIAL’s downgrading statements in its reply to our petition.
The legal norm for airports such as Benbecula and Wick, where there are facilities for an aircraft’s pilot who is making an approach to land in bad weather, is the provision of an ATC approach-control service. That is stated in legislation under the UK Air Navigation Order 2016—the ANO—at article 183.
HIAL appears to compare activity at Benbecula and Wick with its airports at Islay, Tiree, Campbeltown and Barra in order to justify the proposed downgrade based purely on the number of flights. In the case of Benbecula, HIAL fails to mention that the airport can have concurrent movements of aircraft—mainly scheduled or mail flights—that can conflict with each other. The local airspace restrictions around the airport when the QinetiQ ranges are firing is also a factor in air traffic management.
The reason for those omissions appears to be the lack of any local consultation or understanding by HIAL’s consultants, who are working remotely and advising the HIAL board. At present, ATC is the mitigation to avoid airborne conflicts between aircraft. ATC also gives approval to pilots under the Rules of the Air Regulations 2015 as to when they can commence an instrument approach to the airport, as well as the landing and departure order.
An aerodrome flight information service is restricted by the law and licensing under the ANO to providing generic information on other aircraft to pilots. From the information that is provided, pilots take their own course of action. With an aerodrome flight information service, the safety mitigations that are required in bad weather are likely to cause significant delays to scheduled or mail flights, and to stop them from arriving and/or departing at the same time. In addition, ad-hoc charter flights—flights in support of the QinetiQ range at Benbecula, or technical fuel stops in the case of Wick—might be not be possible, unless the aircraft can be operated visually in good weather.
The potential for new scheduled operators to be attracted to Benbecula and Wick might lessen due to the extra safety-related restrictions that will be required at the airport to mitigate the lack of an ATC service. Air operators might, for flight regularity reasons, find it difficult to comply with such restrictive mitigations. We are aware that Wick lost its scheduled services in March.
On controlled airspace, HIAL’s policy appears to be at odds with the Scottish Government’s policy. Linking the provision of ATC to controlled airspace is a future European Union Aviation Safety Agency directive. The United Kingdom Secretary of State for Transport has announced that the UK will leave the agency at the end of 2020.
In addition, we can find no Civil Aviation Authority reference for controlled airspace being a future legal requirement to operate an airport ATC service. CAA has an extensive consultation process on airspace changes. That is somewhat glossed over in HIAL’s plans. For example, an application for controlled airspace at Inverness airport was started in 2014, and Inverness still does not have controlled airspace six years later. Realising that this a big project, HIAL’s consultants appear to have persuaded the board to forget about Benbecula and Wick.
HIAL states that its aim is
“To provide and operate safe, secure and efficient airports which support the communities we serve.”
The proposals are neither efficient, nor do they support local remote communities.
I will hand over to Peter Henderson.