Less process, more judgement: how we read CAP 1616 Version 6. 

By Christopher Weatherburn – Associate Director 

The CAA has published CAP 1616 Version 6, which takes effect on 1 October alongside the Government’s new Air Navigation Directions and Air Navigation Guidance. Views will inevitably firm up as sponsors work through the letters the CAA has issued confirming how the transition applies to their own proposals, but the following sets out our reading of the reforms at this stage.

This is, on its face, a deregulatory exercise – the CAA’s own news release is headlined “Regulator cuts regulatory burden to accelerate airspace modernisation,” and reducing unnecessary burden sits among its four stated reasons for the changes. But our starting point is that the deregulation has a destination. Several of the changes make most sense when read alongside what the UK Airspace Design Service has been asked to do: act, in the CAA’s words, as “a single guiding mind to coordinate and sponsor future airspace changes”.

Designing across an entire terminal manoeuvring area – the dense block of controlled airspace serving several airports at once, in London’s case Heathrow, Gatwick, Stansted, Luton and City – is considerably harder when every sponsor brings its own locally negotiated design principles to the table. Removing those principles and replacing them with a single national hierarchy makes system-wide design something that can realistically be planned. The CAA lists support for UKADS and “a coordinated, system-wide approach to airspace design in London and the South East” among those reasons for the changes, noting that the reform “will have an immediate effect on the proposed airspace changes to the London areas.”

That national hierarchy is worth stating plainly because everything else follows from it. Airspace must now be designed to deliver safety first; then the capacity permitted by planning decisions; then minimal change to areas already overflown below 5,000ft; then the lowest practicable total noise below 5,000ft; and finally, flight efficiency above that altitude. The trade-offs that sponsors and communities once worked through locally have been settled centrally, and in advance.

The headline changes

Anyone who has worked through the old process will notice immediate differences. There are now five stages rather than seven, 43 requirements rather than 113, and a single gateway in place of three. Roughly a quarter of the text has disappeared. The guidance has been split up, with permanent changes in CAP 1616j, non-permanent changes in CAP 1616k, and the CAA’s air navigation functions set out separately in CAP 3299.

Notable changes include:

  • An early check-in with the regulator, but not a green light. A new milestone review at the end of Stage 1 gives Level 1 and Level 2 sponsors technical feedback on their developing design. It carries no decision and no permission to progress – useful guidance rather than a hurdle.  
  • One gateway now stands between a design and the public. The Stage 2 consult gateway has been retained, both Level 1 and Level 2 sponsors must pass it before consultation can begin.  
  • National priorities replace locally agreed ones. Airspace Design Priorities supersede the altitude-based framework, setting a single transparent hierarchy for weighing noise, emissions, and operational efficiency against one another.  
  • Less to assess, and fewer documents to assess it in. Environmental assessment has been aligned to the Air Navigation Guidance 2026: the initial options appraisal, certain metrics and economic assessments have gone, and CAP 1616i has been folded into the main document set.  
  • Room to test ideas properly before committing. Non-permanent changes now follow their own five-step process, with trials extended from six months to up to three years.  
  • Proposals already grouped together stay where they are. Cluster proposals remain on the 2017 guidance and CAP 1616 version 5.1. Moving to the new framework requires every sponsor in the cluster to agree – and all of them to restart from the beginning. 

The extension to trial periods has attracted most of the sector commentary, with the drone and advanced air mobility community regarding it as a route to gathering meaningful operational evidence before committing to a permanent solution. Giancarlo Buono, the CAA’s Director of Safety and Airspace Regulation, has described the intention as tailoring requirements “to the scale and impact of proposals,” reducing burden while maintaining a consistent focus on safety, evidence, and impact.

The more interesting question is what has not changed

Communities will still want to understand why change is needed, how options were developed and they will still expect to see evidence that their views have been heard.

What has changed is where those expectations meet the process. A community that once helped shape a design principle now encounters a hierarchy set nationally, and a design already formed around it.

None of this is softened by a shorter process. In our view, it becomes harder to satisfy, because the framework now leaves considerably more to sponsor judgement, and because the ground on which sponsors must explain their decisions has shifted beneath them.

Where the communications challenge concentrates

Version 6 applies automatically where a proposal designs a block of airspace covering the area managed by more than one airport and is sponsored by NATS (En Route) plc, known as NERL, as the UKADS provider. CAP 3129, the London TMA onboarding process, has been retired, with transition actions to be published on the airspace change portal on 1 October.

There is a detail in that arrangement which deserves more attention than it has had. Under the consolidated London proposal, existing airport sponsors would no longer act as the primary sponsors of the airspace change. Instead, they would participate in a process led by UKADS and NERL. Communities that have engaged with their local airport for years may find that the formal sponsor of a proposal is now UKADS, a service provided by NERL, rather than the airport itself, with the result that the sponsor may not have the same local governance structures or established community relationships. AirportsUK raised a version of this concern during consultation, arguing that airport sponsors should have a clear mechanism to be informed of, and comment on, the development of both the process and the emerging design.

The coherence this delivers is genuine. However, a system-wide design affecting multiple airports raises an obvious question for communities: who is accountable to them, and with whom should they engage? Because the relevant trade-offs are now settled nationally and at an earlier point, sponsors will find themselves explaining decisions they did not take, to audiences who were not present when those decisions were made.

Judgement in place of prescription

Consultation remains the formal route for affected communities, but with greater onus on sponsors to design a strategy appropriate to their scheme rather than following a set pattern. Stage 1 engagement is more tightly defined around information that addresses the statement of need.

Fewer prescribed steps mean fewer places to hide. Why that approach, why that audience, and why that level of engagement was proportionate become the questions that matter, and they are answered through judgement rather than compliance.

That said, the new Air Navigation Guidance also places the expectation of proactive noise engagement into statutory guidance, applying whether or not a process is live.

For sponsors, we believe this creates an opportunity

The strongest airspace change programmes have never relied solely on consultation. They have been built on clear communication, proportionate engagement, strong stakeholder relationships, and a credible evidence base from the outset. That is the approach we have supported across multiple CAP 1616 programmes, for some of the UK’s largest airports.

The process is changing. The importance of trust, transparency and meaningful engagement is not.

If you would like to discuss what Version 6 means for a specific proposal, or how to approach engagement under the new framework, we would be glad to talk.

Further reading:

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