Main_Consultation_Documents_-_Appendix_A_-_Overview_of_CAP1616_process_to_date.pdf
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This document shows how FlyDoncaster are justifying option 3. What do you make of it?
Here’s the straight, structured,
aviation‑focused assessment of how FlyDoncaster/CDC are justifying
Option 3 in the CAP1616 Appendix A you shared — and whether that justification actually stands up to scrutiny.
No politics, no emotion — just the operational and regulatory logic.(As always, confirm details with trusted sources.)
Takeaway
Option 3 is being justified almost entirely on
process compliance and
integration with MTMA, not on traffic demand, safety necessity, or credible operational forecasts.The document
presents Option 3 as a technical optimisation, but the underlying reasoning is thin and heavily dependent on modelling assumptions that the CAA has already described as
“particularly speculative.”
1. The justification is procedural, not operational
The document repeatedly emphasises:
- CAP1616 compliance
- design‑principle scoring
- integration with MTMA
- systemisation
- containment within CAS
But it
does not demonstrate:
- a credible level of traffic requiring CAS
- realistic airline interest
- realistic cargo activity
- realistic fleet mix
- realistic operational complexity
This is a major gap.
The CAA will notice.
2. Option 1 was rejected because NATS refused to support it
This is important.
The document states:
“NATS NERL stated that they cannot support Option 1… for a number of reasons.”
This is the real reason Option 1 died — not because Option 3 was better.
NATS’ refusal forces CDC into a narrower set of viable options.
Option 3 is essentially the
only option left that:
- fits MTMA modernisation
- uses PBN containment
- reduces controller workload
- aligns with CAA policy
This is not a strong justification — it’s a constraint.
3. Option 0 (no CAS) was dismissed on circular logic
The document says Option 0 was rejected because:
“it did not meet the objective… which is to re‑establish controlled airspace.”
This is circular:
- The objective is “re‑establish CAS.”
- Therefore any option without CAS is rejected.
This is not an evaluation — it’s a predetermined outcome.
It avoids the real question:
Does DSA actually need CAS for the level of traffic forecast?
The document never answers that.
4. The FOA justification relies on extremely speculative traffic forecasts
The FOA compares Option 2 and Option 3 using:
- noise
- emissions
- fuel burn
- tranquillity
- biodiversity
- economic benefit
- GA impact
- MTMA integration
- safety
But all of these depend on
traffic forecasts that the CAA has already criticised as:
“particularly speculative.”
If the traffic forecasts are weak, the FOA is weak.
If the FOA is weak, the justification for Option 3 is weak.
5. The NPV difference between Option 2 and Option 3 is negligible
The document shows:
- Option 2: £554.7m
- Option 3: £541.9m
A difference of
2%.
The document admits:
“This cannot be used alone to make a decision.”
This is correct — because the difference is trivial.
So NPV does
not justify Option 3.
6. The noise differences are also negligible
The FOA noise tables show:
- Option 2 better in some contours
- Option 3 better in others
- Differences of 8–18% in small contour bands
- Overall TAG difference of ~2%
The document admits:
“It is very difficult to draw a conclusion between the two options.”
So noise does
not justify Option 3.
7. The real justification is MTMA integration
This is the only area where Option 3 clearly outperforms Option 2.
Option 3:
- uses Radius‑to‑Fix
- is more systemised
- reduces controller workload
- aligns with future MTMA design
- contains tracks more tightly
- reduces CAS volume
This is the strongest argument — and the only one that is genuinely defensible.
But it is
airspace‑network optimisation, not
airport‑specific necessity.
8. What the document
It never addresses:
- whether DSA’s traffic forecasts justify CAS
- whether the fleet mix is realistic
- whether airlines have expressed interest
- whether cargo operators exist
- whether GA impacts outweigh benefits
- whether Option 3 is proportionate to actual demand
These omissions are significant.
Clean synthesis
FlyDoncaster/CDC justify Option 3 primarily on:
- MTMA integration
- PBN containment
- systemisation
- compliance with CAP1616 policy
But the justification is weakened by:
- speculative traffic forecasts
- circular rejection of Option 0
- NATS’ refusal forcing Option 1 off the table
- negligible differences between Option 2 and Option 3
- lack of evidence that CAS is proportionate to demand
Option 3 is not being chosen because it is
objectively better —it is being chosen because it is the
only option that fits CAA/NATS policy constraints while still allowing CDC to pursue CAS.
If you want, I can produce a
side‑by‑side regulatory critique of Option 2 vs Option 3 using
CAP1616 option analysis.