12th January 2020


We are acutely aware of the recent online discussions that centre around various aspects of Rule 11 following publication of a guidance article on the Airspace and Safety Initiative website ( Whilst we welcome open, honest and balanced discussion our company policy prohibits comment on public forums, we publish this information below in good faith to provide further background, comment and clarity regarding some of the points raised.



We are a member of the North West Local Airspace Infringement Team which meets regularly. This consists of attendees from Aerodrome Operators, Civil Aviation Authority (CAA), Air Navigation Service Providers (ANSP), commercial operators, flying schools and other local airspace users within the North West region. Its purpose is to focus in reducing airspace infringements through local initiatives and targeted actions. This includes the Barton ATZ.


Our article was written and published in the spirit of offering further helpful guidance to assist pilots operating to/from and in the vicinity of our ATZ, following a number of significant infringements which had occurred in recent years. We welcome the wider discussions which have taken place, with no intention of rewriting or redefining any interpretation of existing rules and legislation.


Mandatory Reporting

As a responsible Aerodrome Licensee and ANSP which is audited by the CAA we comply with relevant regulations including the Commission Implementing Regulation (EU) 2015/1018, which lays down a list classifying occurrences in civil aviation to be mandatorily reported. Annex III 10(b) specifically states one of these items as “airspace infringement including unauthorised penetration of airspace”. In the UK an ATZ is notified airspace in accordance with the Air Navigation Order 2016 and “Notified” means set out with the authority of the CAA in a document published by or under an arrangement entered into with the CAA and entitled “United Kingdom Notam” or “United Kingdom Aeronautical Information Publication” and “for the time being in force”.


We have sought clarification directly with the CAA regarding the specifics of reporting requirements of infringements of the ATZ, and have received confirmation that the information stated within the published article is the correct interpretation. We welcome this clarity that we have received which confirms that our procedures and reporting processes are being applied correctly in accordance with the requirements and obligations placed upon us as a certified ANSP. 


Where a mandatory report is made this will include any relevant factual information which is then available for the CAA to consider. Once a mandatory report is made, it is then the CAA who will determine any course of action in accordance with CAA document CAP1404, and this does not influence whether a report is made by the Aerodrome Operator/ANSP. Thoughts and opinions around the CAP1404 process are outside the scope of our responsibilities.


Any report is also processed through our own internal Safety Management System, with reports being reviewed by the Aerodrome Safety Committee which aims to treat and reduce any risk from all occurrences through review and educational methods. Recent educational and information awareness campaigns locally have contributed successfully in reducing the number of infringements of our ATZ by approximately 50% and we continue our policy to use information and education to assist in enhancing safety.


Phraseology “Standby”

In relation to discussions around the use of the response “standby” provided by the AFISO to an aircraft, this is not at any time used as control instruction, but as defined within CAP 413 Chapter 2, 2.18 Table 8, its meaning is ‘Wait and I will call you’, and is neither an approval or denial. The AFISO use of the phrase may be used where the AFISO is be engaged in other priority Air Traffic Service tasks, which may include assisting another aircraft, co-ordination, or perhaps dealing with emergency which may not be immediately apparent on the frequency to the aircraft which has called. The AFISO will revert back to the aircraft calling at the very earliest opportunity available to provide information which then allows the flight to be conducted safely within the ATZ in compliance with Rule 11.  

AGCS and ATZ infringements

At Manchester Barton we do not provide an AGCS and so how Rule 11(5) is applied at aerodromes that provide this service that also have an ATZ is outside the scope of our operation, therefore this is a matter for those licensed Aerodromes and the CAA to determine.


Non Radio aircraft

We are an aerodrome which is Prior Permission Required (PPR) and we also accept non radio aircraft. In these circumstances, we would expect a pilot would obtain PPR by telephone prior to departure. At this point if we are able, permission will be granted and aerodrome information provided along with any expected changes to this information. A signal square is provided to indicate the runway in use and light signals also provided. To aid awareness to other aircraft, the AFISO may also provide information of the expected non radio aircraft movement to other aircraft on frequency around the time it is expected and additionally once it is observed. We believe that by following this procedure this is deemed acceptable compliance with Rule 11 where an aircraft is unable to communicate by radio.


ADS-B Trial

Many pilots will be familiar with the current Airspace4All ADB-B trial which we are partaking in at the Aerodrome. (

The purpose of this trial is to demonstrate the possibilities for small GA-oriented airfields to improve situational awareness for ATS staff and pilots. Whilst using the ADS-B display, the AFISO may use the display as a preventative tool for the purpose of assisting a pilot in preventing an infringement where an aircraft may be observed approaching the ATZ.



In all cases regardless of how rules and procedures are interpreted or applied, and the detailed micro analysis of the regulations, in essence to assist in creating a safe ATZ environment for all airspace users we simply ask that pilots plan to ensure that communication is established with the AFISO in good time before entering the ATZ. The overwhelming majority of pilots using our Aerodrome do so in accordance with all requirements, rules, procedures and common sense without problem, and we believe that this common sense approach would be good practice at any location.


Our ongoing aim is to reduce ATZ infringements to enhance safety and we encourage all pilots of the need to apply good and sensible airmanship at all times. Our continuing focus is to provide a friendly, helpful and professional aerodrome in which to welcome our customers and visitors.  


City Airport Ltd

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