I did send comments.
They did accept some (to the point of using my suggested wording).
They did ignore some of points with and without explanation.
I share the same concern as alioth. They did made some response to that in the consultation response document.
We’ll only really know we it get put to practice.
This may have a beneficial effect on the CAA infringements policy (as discussed e.g. here and here) because, I suspect, an airport which can be made to return its no longer much needed CAS may be less keen to MOR every bust just for fun.
OTOH, and this is an issue with UK CAS which few in GA want to talk about, the reasons we have such weird airspace in the UK are
Much UK “big airport” CAS is mostly unused but has to be present because it has to contain the published SIDs and STARs – even if these are generally not flown as published. The only way such an airport can reduce its CAS is by eliminating some of these procedures, and nobody wants to do that because “going procedural” is the backup plan for loss of radar. It has been stated by various UK ATCOs that the UK airline system would collapse in such a case because “going procedural” would reduce capacity by a factor of several times, but this is no doubt secret, and the radar backup provisions are definitely secret.
I have merged this thread with another older one on the same topic.
Peter wrote:
Much UK “big airport” CAS is mostly unused but has to be present because it has to contain the published SIDs and STARs – even if these are generally not flown as published.
I’m VFR only, so I don’t really know this, but AFAIK class E airspace would be wholly sufficient for this purpose, right? So why not just reclassify the airspace in question as class E, which creates much less hassle for VFR flights while IFR traffic will still get a guaranteed service?
Peter wrote:
The only way such an airport can reduce its CAS is by eliminating some of these procedures, and nobody wants to do that because “going procedural” is the backup plan for loss of radar. It has been stated by various UK ATCOs that the UK airline system would collapse in such a case because “going procedural” would reduce capacity by a factor of several times, but this is no doubt secret, and the radar backup provisions are definitely secret.
Yes indeed. It is silly to pretend that in the event of loss of radar then all the CAT in the south-east of the UK would just go procedural and carry on as normal. Total radar failure across the entire area would ground nearly all it.
It is as silly as pretending that when you lose an engine and all gyros and your GPS at the same time in your light MEP (in solid IMC) then you just carry on like a tough guy and fly an NDB approach (holding if necessary) on the compass, and it is no big deal because in theory that stuff is all possible and we should be able to do it. Of course in the real world it’s a mayday with a diversion to the nearest place that can do an SRA and everything is cleared out of your way.
MedEwok wrote:
class E airspace would be wholly sufficient for this purpose
Within the UK ANSP, CAA and consultant writing the safety case, there seems to be some dislike for Class E because it doesn’t provide a known environment.
That then forces ATCO to use the same separation criteria as class G or causes problem to airlines who haven’t written the safety case to operate in class G/E.
This is in the same vein as the over-controlling in class D.
Xtophe wrote:
MedEwok wrote: class E airspace would be wholly sufficient for this purposeWithin the UK ANSP, CAA and consultant writing the safety case, there seems to be some dislike for Class E because it doesn’t provide a known environment.
That then forces ATCO to use the same separation criteria as class G or causes problem to airlines who haven’t written the safety case to operate in class G/E.
This is in the same vein as the over-controlling in class D.
What about Class E + TMZ + RMZ?
We did the Class E before lots of times. AFAIK the main objection by far is that ATC services would have to be provided to light GA flying “IFR” and 99%+ of it is below 2000kg and thus doesn’t pay route charges! And most of the > 2000kg GA, if hacking low level around the UK, just flies “VFR” 
The System (NATS etc) is all too aware that if they introduced IFR charges < 2000kg, practically everybody would fly VFR, in IMC as necessary. A 24/7 radar desk at NATS was claimed to cost £1M/year and that was years ago, so The System really wants the absolute minimum of CAS.
Unless somebody else is paying for the service, and that is what happens when say Norwich gets Class D (the airport pays for the ATC, the radar, etc, and firmly crosses its fingers and hopes and hopes and hopes that the “airline” which is being milked to pay for it all doesn’t “do a Flybe” 
).
arj1 wrote:
What about Class E + TMZ + RMZ?
That seems to solve their (perceived) issues. So that why we end up with E+TMZ or E + (TMZ or RMZ).
I get that, for airports, radar ATC is much more expensive than CAS as a GA barrier
Who owns the radars ? CAA or NATS ?
I guess they were built with taxpayer’s money.
AFAIK, in the UK, almost every airport with CAS and “airline” traffic has on-site radar.
It doesn’t come cheap.
