boscomantico wrote:
has any European country ever, or say in the last 30 years, made any drastic changes in their basic airspace design?
Did Hungary not have a major airspace change to open things up? I could be misremembering.
Yes – a couple of countries have. Hungary and Austria. Not sure it has helped though because they just fill up with RAs.
Another thing which makes airspace change hard is that the airspace structures are basically the result of deals between the national CAAs and the national air forces. For example the large amount of UK Class G is there because
Ireland, I am not sure. It has no significant air force (some turboprops AFAIK) and not being a top-drawer-terrorist target they don’t need one (most air force work these days is intercepting airliners which have flown out of last unit’s radio range). It also has little GA, though no worse than most European countries per square mile.
boscomantico wrote:
What I was thinking is: has any European country ever, or say in the last 30 years, made any drastic changes in their basic airspace design?
Yes. Sweden changed a UK style airspace design (except for the airspace classes and lack of coordination) with “airways” extending to a generally low level – 4500 feet IIRC – to a design where all airspace above FL95 is controlled and nothing is controlled below that outside TMA/CTR.
Norway has very similar to Sweden. Can’t remember exactly how it was before, I only remember airspace to be a non factor. We had these “airways” up there somewhere. They were E if I remember correctly.
Today it is mostly G. No transponder or radio necessary. Then there are TMA/CTR mostly D, but one or two C. In addition there are lots of TIZ and TIA, commercial airports, which is in G, but radio mandatory. IFR and VFR allowed everywhere.
This is how it is. Then there are “unwritten rules”. Below TMAs you get in contact with approach. ATC may direct you there as well, and you may very well end up in C/D airspace to get separation from helicopters flying VFR/IFR. It is also considered good aviation practice to transmit blind on 123.5 when landing on small strips, even if it is just a field. Also monitoring 123.5 is good practice when flying in G.
There is usually no problem getting access to controlled airspace. But, if you come unexpected at busy hours, you can get the rather negative message “stay out of controlled airspace” and only that. A minute or two later, you may get a clearance though.
have you actually ever flown in an area with ADS-B in? I suspect not. I fly in what is probably the busiest airspace on the planet
I have never used ADSB in or out 
but I have used FLARM a lot. FLARM is nice in the context it is intended, but take it out of context, and I have a hard time seeing it’s usefulness. But busiest airspace on the planet? At ENVA there are often military exercises. At one point there where military helicopters in/out at 500 ft, and several planes in holding at 1000 and 1500. 3 layers of holding patterns. CAT in and out constantly. Exactly what an ADSB would help in that circumstance is not very obvious to me.
Sorry for being late to this thread. I’ve spent any free time that I’ve had over the past 10 days working on my response to the consultation. Hence the lack to time to contribute to this thread. I appreciate that this thread has moved on, but I shall attempt to fill in some background information.
The IAA issued an AIC earlier in the year announcing a ‘root and branch’ review of Irish airspace. They held a MS teams briefing session where they invited anyone interested to join and hear what was proposed, and ask questions.
I participated in that meeting it was all very positive. They said that what was driving it was EU regulation 2018/1048 which requires PBN approaches for all IFR runways by Jan 2024, and removal of conventional approached by 2030 (that regulation is worthy of its own thread). They stated that it also required that they make provision for continuous climb operations (CCO) and continuous descent operations (CDO) inside protected (controlled) airspace to facilitate environmental benefits.
But they also stated that the current structure was based on old navigation technology and that they expected when more modern equipment was taken account of, that much class C airspace could be returned to class G.
Comments were invited for the first round of consultation with “everything open for discussion”. We were told that if we had a suggestion, now was the time to make it as everything was being considered.
There were rumours at the time that the IAA were considering lowering the Shannon class C CTA (which covers all of Ireland outside Dublin) from FL75 to FL45, but this was denied by the IAA on the MS Teams meeting.
Comments were submitted, and then as a result we got this current proposed revised design.
Local copy of proposal
You can see the current structure here
EI_ENR_6_1_EN_pdf
In essence what they did was take the current circular CTRs and drew a square which encompassed them and expanded the CTA stubs to match the edge of the squares (doubling the width of the CTA stubs. Some additional controlled airspace was taken in CTAs surrounding Cork/Shannon/Kerry areas jointly.
A tiny sliver of class C to the west of Shannon was returned to class G.
Needless to say this received a very negative reaction from the GA community. Of the 276 comments submitted, not a single comment was accepted! 4 were partly accepted, and the remainder were either not accepted or simply “noted”.
A further MS Teams video call was organised where the GA community could ask questions and seek clarifications before submitting their comments on the proposal. This meeting descended into a farce. It was honestly a truly unprofessional affair that didn’t reflect well on the authority.
It was pointed out that we were told that the process was being driven by the need to provide for continuous climb/descent operation which the airlines were demanding, but yet not a single airline had deemed the issue important enough to submit a comment in support of changes being made. They were asked why the process was pushing ahead with such significant additional class C airspace, if the airlines weren’t interested and the GA community were united against it? There was some shifting in chairs and awkward adjusting before we were told that it was required under EU regulation 2018/1048 to make environmental savings and that they had no choice in that. They did accept that the airlines hasn’t supported the idea.
Another commentator who is an airline pilot based in Ireland stated that in his experience he couldn’t remember ever been denied a continuous descent in Irish airspace, which tallied with the lack of interest in the review from the airlines. He then asked that if the additional airspace taken up by the square CTRs wasn’t needed by the airlines and wasn’t need to encompass the IFR procedures (which were wholly within the current circular ones), then what was the justification for taking the additional airspace? There was a bit of stuttering, mumbling and avoiding the question. But the question was asked again and eventually the IAA said “We gave you square CTRs just to show you what square CTRs look like!” Incredulous, he asked if he had heard them right and that the additional controlled airspace was simply to show us what square CTRs look like, and they confirmed that was the case!
A number of people in the consultation suggested that class E airspace for CTAs might be a reasonable compromise. This would allow airlines to descend under IFR control while at an altitude that would ensure primary radar coverage, allowing for CDO/CCO, without overly affecting GA traffic. The IAA stated that they were bound by their own decision to follow an idea at an EU task force, to only use class C or G airspace and therefore class E airspace could not be considered.
On the MS teams meeting they were asked where we could find out further information about this task force. We learned from their answers that we couldn’t find anything further on it, as it was disbanded in 2009!
There are some thing that might not be obvious here to people who aren’t familiar with flying in Ireland that are relevant.
- We don’t have any very high mountains, but plenty of terrain 1500-3500ft and cloud bases of 1000-3000ft are typical. So large CTR and CTA can be an issue as often you are flying close to or below the tops of terrain. So you might well need an unplanned transit through controlled airspace.
- Outside the airlines, we have virtually no IFR traffic. Very few pilots go on to get any form of instrument qualification.
- Our regional airports get very little traffic. Dublin, Shannon & Cork have a reasonable amount of traffic, but the others very little.
- Waterford and Sligo have no airline traffic whatsoever, despite their significant amount of class C airspace and are getting a significant amount of additional class C airspace under the proposal. How these additional airspace is going to result in environmental benefits is unclear when there is no airlines to benefit from it!
Given that there is so little airline traffic into these airports (in some cases none at all) it’s hard to see how the fuel saving to the airlines from CCO/CDO (which apparently they have no problem getting presently anyway) will be outweighed by the additional fuel spent by GA going around controlled airspace. No assessment has been made of this and no account has been taken of additional fuel burn by GA.
Then, having read the EU Regulation, it turns out that it doesn’t in fact make any requirement for environmental benefits, and doesn’t require provision for CCO/CDO at all! It only requires that PBN procedures be introduced!
I have heard a number of people offer the opinion that this was never intended as serious proposal. Instead it was supposed to create a state of horror and fear, so that when it’s rowed back, that the GA community will so relieved that they will be willing to be accepting something that isn’t as bad; something that they wouldn’t have been willing to accept if it was the first proposal.
I’m inclined to agree with that assessment. There are a few things that make this look like it was never seriously considered.
For example, these CTR/CTAs were clearly just thrown together.
Even a cursory look would tell you that the narrow gap between the two CTRs is a dangerous choke point. (The IAA in their own strategic plan for GA, indicate that they see mid air collisions as a risk that needs to be addressed). And the CTA for Connaught overlapping the Sligo CTR and CTA is just stupid. This could never have gotten over a simple check, which means that it never got even a simple check. Presumably because it was never going to be implemented.
Also the Kerry CTA doesn’t comply with EU regulations for CTAs in that it has terrain sticking into it! That’s not a mistake that the IAA routinely make. If it was a serious proposal, this would have been checked and found.
I understand that they have already decided to abandon the square CTR ideas, but nothing official said yet. But what comes next we’ll have to wait and see.
The plan is for an updated proposal on 9 September. There will be another MS Teams meeting on 16 September to answer questions from the GA community. Submissions on this proposal will need to be in by 7 October.
Then their final airspace version will be published on 4 November. This is what they will be putting into place and no further comments accepted.
From what I can see, the airlines aren’t pushing for this. The GA community is united against it. EASA isn’t pushing for it. The only people who have spoken in favour of it in the consultations are the ATC at the regional airports and the IAA themselves, and one individual airline pilot.
Regarding the need for flight plans to cross controlled airspace, that is a legal requirement in Ireland. They take a flight plan to mean one filed in the AFTN system, not an abbreviated one on the radio. They state that you can file one over the radio (a full one) but actively discourage it, and it’s likely to be refused in practice. I’ve not had much issue getting transits without filing one, and many people don’t bother, but it seems to be highly variable. Some people have lots of difficulty. I suspect it’s ATC unit or controller based. And in fairness, I don’t often cross controlled airspace without filing a flight plan. I always plan my flights on EasyVFR, so filing a flight plan is just a couple of extra taps, and no cost for filing, so there is little reason for me not to.
Regarding access to controlled airspace, this is unit and time dependent. Access is very difficult around Dublin airspace, even in parts of the CTA where there isn’t airline traffic. Around the other airports it’s generally good IF A) you can get sufficient altitude to make contact (can be an issue on the edge of the CTR for Sligo & Connaught) and B) they aren’t expecting an airline in the next 20 minutes, and C) the controller isn’t on a break!
It’s not unheard of to be told to wait outside the zone for an aircraft that is 15 minutes away from the CTR (so at least 20 minutes to touchdown). One commenter in the original consultation point out that in Waterford, the local aircraft were being given unofficial NOTAMs about controller breaks. The controller would be on a break and couldn’t provide a control services. So they would not be allowed to depart, arrive or operate in the zone during this break period. However the NOTAM would never be officially published, meaning that the airspace would not officially downgrade to class G. In other cases at other airports, controller breaks would be NOTAMed and the airspace officially downgrades to class G, but Shannon FIS tells pilots that they can’t enter it while it’s class G, until the controller comes back on duty!
Of course operating in controlled airspace while doing aerobatics or upper air work for training/PFLs etc provides its own difficulties.
Thank you for the additional information. I hope the GA community can get through to the IAA about this, as it sounds like there is little to no good reason to implement pretty much any of it. The meeting you describe sounds like a joke. Are the teams meetings open to all or is it invite only? I would be interested in joining if possible. I fly in Ireland often and was based in both Shannon and Dublin at various times as an airline pilot, and operated commercially into many of the airfields mentioned in the proposal, and I can not honestly say I ever had an issue with the way things were, nor do I see what I might gain from the changes.
Pirho wrote:
Are the teams meetings open to all or is it invite only?
They are open to all. Though I suspect the format for the next one will change in order to screen and control the questions so they filter out awkward questions!
The link will most likely be published on the IAA website. If I remember at the time, I’ll post a link to it here.
Thanks Dublin for the the deep details. Some comments/remarks:
- Airlines need protected airspaces for CDOps around airports. In Germany we have regular near misses between gliders and airliners at airports where part of the descent is happening in unprotected airspace. Yes, the glider has the way of right but airline pilots (imho correctly) claim that it is simply impossible to avoid a glider while preparing for the approach, etc.
- I wouldn’t take the fact that the airlines do not show up in public hearings as a sign that they do not want the change. First I would expect they have other means of communication to the IAA and second why should they show up and ask questions if they get 120% of what they want?
- As you can read in many threads also on this forum, circular CTRs are really not a good idea. Pilots do always complain that it is impossible to visually track the borders of such CTRs and therefore airspace infringements are naturally given (with arguments like "we need to watch out and therefore can not always observe the circle on the GPS). Therefore to avoid airspace infringements and overload of esp. VFR pilots, straight lines as airspace borders are actually much better!
circular CTRs are really not a good idea.
Circular CTRs/CTAs (aka. the classic inverted wedding cake) were a great idea during pre-GPS days when a VOR/DME was centered on the aerodrome and the aerodrome itself had cross-runways.
One would look at the DME to get an idea where the new raised base of CAS was the further they were away from the airport. Its simplicity helped avoid infringements. It still remains a preferred solution used in the USA, Canada and Australia.
James_Chan wrote:
One would look at the DME to get an idea where the new raised base of CAS was the further they were away from the airport.
Fully agree – for DME equipped aircraft this is an easy way.
