Irish Aviation Authority Policy LAND USE PLANNING AND OFFSHORE DEVELOPMENT

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1 Irish Aviation Authority Policy LAND USE PLANNING AND OFFSHORE DEVELOPMENT Version 1: 10 December 2014 Aviation and Construction Co-existing

2 CONTENTS Amendment Record Executive Summary 1: Introduction 2: Obstacles to Aircraft in Flight 3: Safeguarding

3 : Wind Turbines 5: Safeguarding Surveillance Systems from Wind Farm Effect 6: Aeronautical Data 7: Aeronautical Surfaces Screening Evaluation Tool 8: Stakeholder Communication

4 02 AVIATION AND CONSTRUCTION CO-EXISTING - Land Use Planning and Offshore Development DOCUMENT RECORD The version history below records the development of the Irish Aviation Authority s Policy on Land Use Planning and Offshore Development. It should be used to record updates or amendments to the document which may be required in the light of developments in the subject area. Version No. Subject Source Chapters affected Date 0.11 Draft for IAA Consultation IAA Policy on Land Use IAA All 4 Sept 2014 Planning and Offshore Development 0.12 Draft for Public Consultation All 6 Oct Released Issue All 10 Dec 2014

5 Irish Aviation Authority Policy - Version 1: 10 December EXECUTIVE SUMMARY 1 Background The Irish Aviation Authority (IAA) is a commercial semi-state company under the aegis of the Department of Transport, Tourism & Sport. The principal statutory functions of the IAA are: To provide or make arrangements for the provision of air navigation services in Ireland s airspace (including adjacent airspace under international agreements) and to provide communication services over the eastern part of the North Atlantic Region; to provide terminal (air traffic control) services at Cork, Dublin and Shannon airports; to regulate the safety of Ireland s civil aviation industry and to oversee civil aviation security in the State. The IAA is required to exercise its functions in accordance with the standards laid down by the International Civil Aviation Organisation (ICAO), European Union legislative requirements and national regulations. A key aviation objective is to provide a safe airspace environment for the operation of aircraft. In this regard the IAA publishes aeronautical information including maps and charts containing, inter alia, topographical and man-made obstacle data to enable aircraft operating agencies and pilots to plan and conduct flights in a safe and orderly manner. In addition, to support safe and efficient air traffic control services, the IAA has in place a Communications, Navigation & Surveillance (CNS) infrastructure consisting of radar stations, navigation aids and technical facilities located at Cork, Dublin and Shannon airports, Ballygirreen (near New-Market-on-Fergus, Co. Clare) and at various remote sites throughout the State. In its capacity as safety regulator, the IAA specifies its requirements for licences, certificates, approvals, permits and matters of that nature governing activity in the aviation sector. These requirements must be met in order to obtain and/or continue to exercise the privileges of the licence or other form of approval issued by the Authority. In many cases other legislation, including legislation which is not specifically directed at aviation, may also apply to the activity and Government departments or other bodies have statutory responsibility in the area. For example, whereas the IAA grants the licence to operate as an aerodrome it has no regulatory powers to approve or reject a planning application for an aerodrome. This power is vested in the relevant Planning Authority and an Bord Pleanála which have statutory responsibility for land use planning in Ireland. The IAA is, however, a prescribed body which will be consulted where it appears to the (planning) authority that a (proposed) development might endanger or interfere with the safety of, or the safe and efficient navigation of aircraft. Any development (e.g. buildings, masts, wind turbines, cranes, landfills, excavation and spoil, including vegetation etc.) near an aerodrome or its CNS facilities may be assessed for its potential to affect the safe operation of aircraft. Developments outside the vicinity of aerodromes may also be relevant if they are near CNS facilities and/or are 45 metres or higher above ground or water.

6 04 AVIATION AND CONSTRUCTION CO-EXISTING - Land Use Planning and Offshore Development 2 Safeguarding Aerodromes and Technical Facilities Government policy on energy from renewable sources is likely to involve the construction of onshore and offshore wind farms, with associated distribution networks, which may constitute obstacles to air navigation and/or adversely affect the IAA s technical facilities and/or those of other air navigation services providers in the State. Offshore wind farms are excluded from the provisions of the Planning & Development Act 2000 but are subject to the Foreshore Acts which are administered by the Department of Environment, Community and Local Government. The IAA has directed that operators of aerodromes licensed for public use have in place a procedure for safeguarding their aerodromes by monitoring and assessing planning applications for proposed developments which may penetrate airspace protected for arriving/departing aircraft or negatively affect navigation aids used by aircraft and for the provision of air navigation services. Operators of licensed aerodromes which are not subject to the safeguarding direction, and operators of unlicensed aerodromes (e.g. airstrips, helipads etc.) and sites for other aviation activities such as gliding, ballooning, parachuting etc. are advised to take steps to protect their locations from the effects of possible adverse developments by establishing an agreed consultation procedure between themselves and the local planning authority. All of these developments may be assessed from the perspective of aviation safety. This document sets out IAA policy but other organisations involved in aviation will also be interested in developments which may affect their activities.

7 Irish Aviation Authority Policy - Version 1: 10 December The IAA has a two-step process to determine if a proposed development is likely to have an adverse impact on its technical facilities. This process assists the IAA in deciding the position it will communicate to the relevant planning authority in respect of such development: 1. Where the IAA considers that a planning proposal/planning query does not infringe the building restricted area (BRA) surfaces as described in ICAO EUR DOC 015 then the planning authority is advised that the IAA has no objection to the proposal as far as its technical facilities are concerned. 2. Where the IAA considers that BRA surfaces are infringed then the IAA will advise that further expert engineering analysis is required. This analysis is the responsibility of the planning applicant or developer. Early engagement at the pre-planning stage between developers and aerodrome operators/ air navigation service providers can help to resolve potential aviation issues associated with proposed developments to the satisfaction of all parties. 3 Support to Stakeholders ASSET It is clear that a collaborative, proactive and consultative approach between the aviation, construction and wind energy industries is necessary in the area of land use. To facilitate this, the IAA has put in place a dedicated cloud based system to assist all stakeholders in carrying out their respective functions. Known as the Aeronautical Surfaces Screening Evaluation Tool (ASSET), this software system provides the IAA with the facility to meet several of its aviation safety requirements, one of which relates to storage and publication of electronic data for obstacles, terrain, navigation aids, aerodromes and associated airspace protection surfaces. Furthermore, ASSET has advanced capabilities, including two-dimensional (2D) and threedimensional (3D) visualisation and multi-layer functionality which facilitate the assessment of a proposed development from an obstacle perspective. It is user friendly and once data related to a proposed development is entered via the web, it will provide an initial indication as to whether it is likely to be an obstacle affecting aviation safety or if further evaluation is required. ASSET provides full traceability of data while meeting the stringent EU aeronautical data quality standards required for aviation.

8 06 AVIATION AND CONSTRUCTION CO-EXISTING - Land Use Planning and Offshore Development ASSET can be used free of charge by developers, builders, aerodrome operators, air navigation service providers, aircraft operators, planning authorities, government departments, their agencies and any other stakeholder with an interest in the subject area saving time and resources by providing information on the potential impact on aviation of any proposed development or construction, temporary or permanent, in the State. Within the framework of this document, specific issues will have to be addressed on a case-bycase basis, as it is not possible to prescribe a standard solution or mitigation for all situations where a conflict between development and aviation arises. The IAA specifies its requirements for licences, certificates, approvals, permits and matters of that nature governing activity in the aviation sector 4 Conclusion The IAA is confident that the publication of this policy on Land Use Planning and Off-Shore Development, combined with utilisation of ASSET, will provide for communication between the aviation, construction and wind energy industries, support the planning authority function and enhance aviation safety. Further information on this Policy Document may be obtained from: Corporate Affairs Department Irish Aviation Authority The Times Building D Olier Street Dublin 2 Note: This document supersedes and replaces the IAA publication Irish Aviation Authority Air Navigation Services Policy on Consultation by Planning Authorities in Relation to Protection of ATM Systems & Facilities from Buildings in or close to Restricted Areas Version 1.0, dated 16th November 2007, 1st Edition.

9 Irish Aviation Authority Policy - Version 1: 10 December A key IAA objective is to ensure a safe airspace environment for the operation of aircraft.

10 08 AVIATION AND CONSTRUCTION CO-EXISTING - Land Use Planning and Offshore Development 1: INTRODUCTION 1.1 The Irish Aviation Authority The Irish Aviation Authority Act, 1993, as amended, establishes the Irish Aviation Authority (IAA) inter alia, to: 1. Provide or make arrangements for the provision of air navigation services in airspace assigned to Ireland by International Convention (including adjacent airspace under bilateral agreements) and to provide communication services over the eastern portion of the North Atlantic Region; 2. To provide terminal services (including air traffic control) at Cork, Dublin and Shannon airports; 3. To regulate the safety of Ireland s civil aviation industry; 4. To oversee the security of civil aviation in the State. One of the main objectives of the IAA is to ensure a safe airspace environment for the operation of aircraft and to this end it publishes specific aeronautical information, including maps and charts, containing data on topographical and man-made obstacles to enable pilots and aircraft operating agencies to plan and conduct flights in a safe and orderly manner. In addition, to support safe and efficient aircraft navigation and air traffic control services, the IAA has in place a Communications, Navigation & Surveillance infrastructure consisting of radar stations and other technical facilities located at Cork, Dublin and Shannon airports, Ballygirreen (near New- Market-on-Fergus, Co. Clare) and at various remote sites throughout the State which it must safeguard from developments which could adversely affect the safety-critical functions they perform. The IAA is required to exercise its functions in accordance with the standards and, as far as possible, the recommended practices laid down by the International Civil Aviation Organisation (ICAO) 1, European Union legislative requirements and national regulations. 1 ICAO is a UN specialised agency, created in 1944 upon the signing of the Convention on International Civil Aviation. It develops international Standards and Recommended Practices (SARPs) for all aspects of aviation which States use to develop legally-binding national civil aviation regulations or, in the case of the EU, legal instruments which are binding on member States. There are currently over 10,000 SARPs reflected in the 19 Annexes to the Chicago Convention which ICAO oversees, and it is through these SARPs and ICAO s complementary policy of auditing and capacity-building that today s global air transport network is able to operate over 100,000 daily flights, safely, efficiently and securely in every region of the world.

11 Irish Aviation Authority Policy - Version 1: 10 December In its capacity as aviation safety regulator the IAA specifies requirements for the grant of licences, certificates, approvals, permits and matters of that nature governing activity in the aviation sector. These requirements must be met in order to obtain and/or continue to exercise the privileges of the licence or other form of approvals. In many cases other legislation, which is not specifically directed at aviation, may also apply to the activity and Government departments or other bodies may have a statutory responsibility in the area. For example, whereas the IAA grants a license to operate an aerodrome 2, it has no regulatory powers to approve or reject a planning application for an aerodrome. This power is vested in the relevant Planning Authority and/or an Bord Pleanála which have statutory responsibility for land use planning in Ireland. Regulations made pursuant to the Planning and Development Act 2000 (as amended) take account of the IAA s role by providing that it is a prescribed body which will be consulted where it appears to the (planning) authority that (a proposed) development might endanger or interfere with the safety of, or the safe and efficient navigation of aircraft. 1.2 Airspace Users Airspace users in Ireland fall into four categories. Most will be familiar with the first category which is the commercial air transport activity of airlines carrying fare paying passengers. The number of these flights is growing and this trend is expected to continue year on year, not only with mainstream airlines, but also in the use of business jets and commercial helicopter flights. The second category is military aviation which does not come under the regulatory jurisdiction of the IAA. The Irish Air Corps (IAC) of the Defence Forces operates a significant number of aircraft which may operate in a different manner from civil aircraft in the activities they undertake from time to time. In addition, military aircraft or other State aircraft may require special consideration with regard to airspace usage. Moreover, military air traffic control may handle civil aircraft which they have permitted to enter airspace designated or assigned for military use. The IAA has a two-step process to determine if a proposed development is likely to have an adverse impact on its technical facilities. The process findings assist the IAA in deciding the position it will communicate to the planning authority in respect of such development. This process is described in Chapter 3 - Safeguarding. 2 aerodrome means a defined area (including any buildings, installations, and equipment) on land or water or on a fixed, fixed offshore or floating structure intended to be used either wholly or in part for the arrival, departure and surface movement of aircraft.

12 10 AVIATION AND CONSTRUCTION CO-EXISTING - Land Use Planning and Offshore Development The third category is known collectively as general and sport aviation and covers a wide spectrum of activity mainly consisting of small aircraft, helicopters, gliders, microlights, hot air balloons, para-gliders or hang gliders, remotely piloted aircraft systems (RPAS, also known as drones) etc. Whereas the majority of this category of airspace user falls into the recreational and pleasure flying domain, some general aviation operators may make their living by providing pleasure flights, pilot training, parachute flights, aerial work such as photography, geological and ordinance survey, gas and electricity infrastructure inspection amongst others. More details on civil aircraft categories and the aviation standards and permissions/approvals applicable to them may be found on the IAA website. The fourth category comprises flights, some of which are commercially operated, fulfilling important roles such as support to the Garda authorities, search and rescue flights, medical evacuation and organ donor delivery flights, fishery protection, pollution surveillance etc. Such flights are normally operated under the auspices of the Irish Coast Guard (IRCG) or the Irish Air Corps. This category of airspace user requires particular consideration when making decisions that may affect their ability to safely conduct their activities, which can in themselves involve safety of life services. 1.3 Aerodromes The IAA licenses aerodromes in Ireland. Two types of licence are issued: 1. A Public Use licence for aerodromes used by aircraft carrying fare paying passengers such as the three State aerodromes Cork, Dublin, Shannon and the non-state aerodromes such as Donegal, Waterford, Weston, Inismore (Arran Islands); 2. A Private Use licence mainly for private aircraft operations but at which certain activities such as pilot training and parachuting may be permitted. (e.g. Abbeyshrule, Bantry, Trevet Clonbullogue). A list of licenced aerodromes is contained in the Aeronautical Information Publication (AIP) - Ireland 3, Part 3 Aerodromes (AD), and published on the IAA website. Aviation regulations permit the operation of unlicensed aerodromes (e.g. a hospital helipad or flight strip at a private residence or farm). There are approximately sixty such aerodromes in the State. It is the responsibility of the pilot using this category of aerodrome to be satisfied it is suitable for use. The aerodrome owner should ensure that the site is safeguarded against unacceptable obstacles. 3 An AIP is a document which each Member State of ICAO is required to publish containing aeronautical information of a lasting character essential to air navigation. It lists regulations, aviation procedures and other information pertinent to the flying of aircraft in the particular State to which it relates.

13 Irish Aviation Authority Policy - Version 1: 10 December Air Navigation Services Providers (ANSP) Whereas the IAA is the main provider of air navigation services in the State and provides air traffic control services at the three State aerodromes, certain air navigation services (e.g. air traffic control, flight information and alerting service) are provided by the operators of most of the non-state public use aerodromes (e.g. Donegal, Sligo, Ireland West Airport Knock, Kerry, Waterford and Weston). These ANSPs own and operate technical systems located at their aerodromes to support the safe operation of aircraft and the air navigation services provided by them. As a provider of meteorological services to aviation, Met Eireann is also an ANSP and operates weather radar facilities at Dublin and Shannon airports and meteorological stations located throughout the State. 1.5 Planning Authorities In Ireland the Minister for the Environment, Community and Local Government is responsible for developing planning policy and legislation. The physical planning system in Ireland is operated on the ground variously by local planning authorities, County Councils, County Borough Corporations, Borough Corporations and Town Councils. Decisions of the planning authorities can, for the most part, be appealed to An Bord Pleanála, the planning appeals board. The Department is precluded from any interference in these decisions. The main features of the planning system are: Making development plans; Planning decisions; Exempted development; Appeals against planning decisions; Planning enforcement. The Irish Aviation Authority has no regulatory powers to approve or reject a planning application but is a prescribed body which will be consulted where it appears to the (planning) authority that (a proposed) development might endanger or interfere with the safety of, or the safe and efficient navigation of aircraft It should be noted that offshore constructions such as wind farms, which can have the same negative effects on aviation as those on land, are excluded from the provisions of the Planning & Development Act 2000 but are subject to the Foreshore Act 1933 (as amended) which is administered by the Department of the Environment, Community & Local Government. The drafting of a Maritime Area and Foreshore (Amendment) Bill was approved by the Government in July It is expected that the Bill will be enacted in 2015 and will, inter alia, align the foreshore consent process with the land use planning process (see Chapter 4 -Wind Turbines).

14 12 AVIATION AND CONSTRUCTION CO-EXISTING - Land Use Planning and Offshore Development 2: OBSTACLES TO AIRCRAFT IN FLIGHT 2.1 Determination of an Obstacle The IAA (Obstacles to Aircraft in Flight Order) S.I. No. 215 of 2005 defines obstacles to aircraft in flight for the purpose of airspace protection at, and in the vicinity of aerodromes and elsewhere in the State and specifies reporting and information requirements with respect thereto. In general, the Order provides that a person shall not erect or construct in the State, an object extending 45 metres or higher above ground or water surface level which may penetrate navigable airspace 4 without first notifying the IAA in writing at least 30 days prior to such erection or construction. The Order also states that an object would be an obstacle to air navigation in the vicinity of an aerodrome if would result in the vertical distance between any point on the object and the established minimum aircraft altitude or height for the type of approach being conducted to be less than the required obstacle clearance altitude or height. It also provides that the IAA may require a person to make available to it information relating to an obstacle, including its geographic latitude and longitude, elevation and height and that the IAA may require the conduct of an aeronautical study to determine the significance of a proposed obstacle if it is in the vicinity of an airport. An aeronautical study is the investigation of a problem concerned with a particular phase of flight, identifying possible solutions and selecting the one most acceptable from the point of view of flight safety. It is the policy of the IAA to ensure that operators of aerodromes licensed for public use and air navigation service providers have a system in place to monitor and assess planning applications for development in the vicinity of their aerodromes (see Chapter 3.0 Safeguarding). The system consists of a process whereby planning applications in the vicinity of a licensed aerodrome will be forwarded to the aerodrome licensee and/or the air navigation service provider by the local planning authority for assessment as an obstacle. In this regard, the elevations of the obstacle limitation surfaces (OLS) 5 (see paragraph 2.5 PANS-OPS) or an approximation of the maximum permitted structure height taking ground elevation into consideration, should be clearly indicated on an aerodrome safeguarding map and lodged by the aerodrome operator with the local planning authority(s) responsible for land use planning in the vicinity of the aerodrome concerned. In the case of Cork, Dublin and Shannon aerodromes, the IAA as the provider of terminal services is responsible for the safeguarding of their PANS- OPS surfaces. The IAA will assess and comment on planning applications in respect of structures outside the vicinity of aerodromes. This airspace is referred to as the en-route area (e-tod area 1 see paragraph 6.4). 4 Navigable airspace means airspace above the territory of the State which is available for the flight of aircraft. 5 Obstacle Limitation Surfaces means a series of imaginary surfaces in space with specific dimensions and gradients which define the limits to which objects may project vertically into the airspace surrounding an aerodrome so as to permit aircraft to be operated safely.

15 Irish Aviation Authority Policy - Version 1: 10 December Marking and Lighting of Obstacles General requirements for the marking and lighting of obstacles on or near aerodromes and objects which the IAA has deemed to be en-route obstacles (e-tod area 1) are published in the document Licensing Requirements for Public Aerodromes (ALM 002) on the IAA website. The marking and/or lighting of obstacles is intended to reduce hazards to aircraft by indicating the presence of the obstacles. It does not necessarily reduce operating limitations that may be imposed by an obstacle. The IAA may require the marking and/or lighting of any object in the interest of aviation safety. The responsibility for marking and lighting obstacles on aerodromes must be determined between the aerodrome authority and the owners of the structures. For obstacles outside the aerodrome property the responsibility rests with the IAA and the owners of the structures. The IAA may impose operating restrictions on the aerodrome if the requirements for lighting and/ or marking are not met. 2.3 Shielding The principle of shielding is employed to permit a more logical approach to restricting new construction and prescribing obstacle marking and lighting. Shielding principles are applied when some object such as natural terrain, already penetrates above one of the obstacle limitation surfaces. If the IAA considers that the nature of the object is such that its presence may be described as permanent, then additional objects within a specified area around it may be permitted to penetrate the surface without being considered as obstacles. The original obstacle is considered as dominating or shielding the surrounding area. No obstacle can be considered as shielded if it is closer to a runway than the shielding obstacle. Notwithstanding the principle of shielding the IAA reserves the right to consider any new obstacle and to take appropriate action to protect the safety of aircraft in flight. It is important for aviation stakeholders to note that light emitting diode (LED) type lighting on obstacles may not be detected by a pilot s night vision equipment and in the case of wind turbines the obstacle lighting on the nacelle may be a significant distance below the tips of the rotor blades.

16 14 AVIATION AND CONSTRUCTION CO-EXISTING - Land Use Planning and Offshore Development 2.4 Dangerous lights In aviation, specific lights are established for the purpose of aiding air navigation. They comprise amongst others, lights marking obstructions which affect en-route navigable airspace, obstructions at or in the vicinity of aerodromes, lights to guide pilots navigating to and conducting an approach or departure at an aerodrome, and runway, taxiway and apron lights to aid manoeuvring on the aerodrome surface. Such lights are termed aeronautical ground lights and any light which may be confused with or mistaken for a ground aeronautical light has the potential to hazard an aircraft navigating in the air or on the ground. The IAA s Aerodromes and Ground Visual Aids Order, S.I. No 355 of 2008 provides that: A person shall not exhibit any light which: (a) by reason of its glare is liable to endanger aircraft taking off from or landing at an aerodrome; or The Order also provides that an authorised officer of the IAA may take certain steps to extinguish such light and to consult with the appropriate lighthouse authority in the case of a light which is or may be visible from any navigable waterway. To protect the safety of aircraft against the hazardous effects of laser emitters (e.g. laser displays) laser beam free zones are established around aerodromes licensed for public use. Whereas it is not directly pertinent to land use and off-shore development, it is appropriate when considering the subject of dangerous lights, to refer to Section 43 of the State Airports (Shannon Group) Bill 2014 which makes it an offence to deliberately or recklessly dazzle or distract a pilot or other relevant personnel by directing a light in their direction. This is intended to deal with incidents of persons using a laser to dazzle or attempt to dazzle the pilot of an aircraft or other aviation personnel. A person convicted of such an offence is liable to a fine or imprisonment or both. (b) by reason of its liability to be mistaken for an aeronautical light is liable to endanger aircraft. If any light which appears to the Authority to be such a light as aforesaid is exhibited, the IAA may cause a notice to be served upon the person who is the occupier of the place where the light is exhibited or has charge of the light, directing that person to take such steps as may be specified in the notice for extinguishing or effectively screening the light and for preventing the exhibition thereafter of any similar light.

17 Irish Aviation Authority Policy - Version 1: 10 December Procedures for Air Navigation Services Aircraft Operations (PANS/OPS) PANS-OPS approach surfaces are used in the design of instrument approach procedures (IAPs) which are designed to safeguard an aircraft from collision with obstacles during an instrument flight (i.e. an aircraft relying on ground and/ or space based technical facilities and aircraft based instruments for vertical and/or horizontal guidance). For non-precision approaches (two dimensional guidance only) these surfaces are easily defined. For precision approaches (three dimensional guidance) the obstacle free airspace is more complex. Two methods of assessing the obstacle environment for the determination of minimum safe altitudes including obstacle clearance altitude/height (OCA/H) 6 are currently used for precision approaches by trained and certificated flight procedures designers. It is not necessary to describe these methods in this policy document. Objects which penetrate obstacle limitation surfaces (OLS see footnote 5 on page 12) may in certain circumstances cause an increase in the OCA/H for an instrument approach procedure or any associated visual circling procedure for an aerodrome. Criteria for evaluation of obstacles are contained in Procedures for Air Navigation Services Aircraft Operations (PANS- OPS) (ICAO Doc 8168). The IAA has published Aeronautical Services Advisory Memorandum ASAM No 015 Guidance Material on Instrument Flight Procedure Obstacle Surfaces which contains a complete description of the surfaces concerned. Instrument flight procedures have been developed for most of the public licensed aerodromes in Ireland and can be found in the AIP section AD 2 AERODROMES. 6 Obstacle Clearance Altitude/Height is described as the lowest altitude or height above the aerodrome elevation or the elevation of the relevant runway threshold at which a missed approach must be initiated to ensure compliance with applicable obstacle clearance criteria.

18 16 AVIATION AND CONSTRUCTION CO-EXISTING - Land Use Planning and Offshore Development A detailed examination of the effect of a proposed development on instrument flight procedures is normally conducted by a qualified procedures designer who will consider the following: 1. Departure Routes including Standard Instrument Departures (SID); 2. Standard Instrument Arrival Routes (STAR); 3. Area Navigation (RNAV) routes; 4. Sector Entry and Exit points; 5. Holding points (including the holding areas); 6. Missed Approach Routes; 7. Minimum Radar Vectoring Altitudes; 8. Final Approach Tracks; 9. Visual Reporting Points; 10. Published Instrument Flight Procedures (IFP) for the aerodrome; 11. Navigation aids and surveillance systems; 12. Minimum en-route altitude (MEA); 13. Future airspace and operational requirements where aerodrome growth is anticipated. Any construction which constitutes an obstacle affecting the above can influence a proposal for such construction. Developers can use the IAA s Aeronautical Surfaces Screening Evaluation Tool (see Chapter 7- ASSET) which will provide an initial indication as to whether any aeronautical surface is penetrated by a proposed construction near any aerodrome for which Instrument Flight Procedures are published and if a detailed examination or aeronautical study may be necessary (see paragraph 2.1). 2.6 Flight Inspection Navigation aids are routinely checked on the ground and have ground-based monitoring systems to prevent invalid signals from being transmitted. However, beyond these monitors the radiated signal can be adversely affected by interference or obstructions. When a pilot is relying on a signal to guide him/her through the clouds and a safe distance from obstructions on the ground, the signal must perform within internationally established tolerances for continuity, integrity and accuracy. In the same way each instrument flight procedure, be it for the departure, en-route or arrival phase of flight, is carefully developed and flight checked to a stringent set of criteria to ensure it is safe and efficient for pilots to fly. The process of checking the performance of navigation aids and associated flight procedures with aircraft equipped specifically for the purpose is known as flight inspection and is carried out with mandatory periodicity. Pilots of aircraft conducting flight inspections may be required to fly at altitudes below that at which routine flights are conducted. If obstructions preclude this and the flight inspection cannot be completed in accordance with regulations, the navigation aid and/or the procedures it supports may be subject to restrictions or, in the worst case, withdrawn from service. This could have a negative commercial impact on the operation of the aerodrome concerned. It follows that aerodrome licensees and air navigation service providers need to consider and developers need to be aware of flight inspection requirements particularly with regard to proposed constructions in the vicinity of aerodromes licensed for public use.

19 Irish Aviation Authority Policy - Version 1: 10 December Parachuting All parachute drops from civil registered aircraft in Irish Airspace are regulated by the IAA and must be conducted in accordance with the requirements of Article 7 of Irish Aviation Authority (Rules of the Air) Order, 2004, S.I. No. 72 of For the purposes of this Policy Document two elements of parachuting activity are considered: Parachute Landing Area (PLA): the terrain onto which parachute descents are made; Dropping Zone (DZ): the notified portion of airspace within which parachute descents are made. It is the parachuting operator s responsibility to be satisfied that the PLA is suitable for the intended purpose, taking into account the capability of the parachutists, the dimensions of the landing area, the dimensions and relative positions of available overshoot and undershoot areas, proximity to any buildings, power lines or anything else which may be a hazard to parachutists and the presence of other activities on or near the PLA. 2.8 Remotely Piloted Aircraft Systems (RPAS) The IAA has published Aeronautical Notice 0.63/2014 titled the Operation of Remotely Piloted Aircraft Systems (RPAS) in Irish Airspace which directs that certain categories of RPAS shall not be operated in the State s airspace without a written permission from the IAA. In addition guidance material on such operations is available on the IAA website. The Aeronautical Surfaces Screening Evaluation Tool (ASSET) can be used by RPAS operators (See Chapter 7) to provide an initial indication as to whether a proposed operation is likely to impact airspace protected for use by aircraft in the vicinity of aerodromes or other designated airspace. In Ireland, parachuting normally takes place at licensed aerodromes and the aerodrome operator is responsible for safeguarding the site. More information on parachuting, including a list of authorised parachute centres, may be found on the IAA website.

20 18 AVIATION AND CONSTRUCTION CO-EXISTING - Land Use Planning and Offshore Development An obstacle is described as any fixed or mobile object, temporary or permanent, which extends above a defined airspace surface intended to protect aircraft or stands outside this surface and is assessed as constituting a hazard to air navigation.

21 Irish Aviation Authority Policy - Version 1: 10 December : SAFEGUARDING 3.1 Safeguarding Aerodromes Holders of a public use aerodrome licence should have in place a system for monitoring local authority planning applications to identify any proposed construction of objects within a radial distance of at approximately 15 kilometres from the aerodrome reference point, where such objects have the potential to infringe areas of obstacle limitation surfaces (OLS) appropriate to the classification and code of each runway either existing or planned. In addition, licensees should safeguard their aerodromes against any land development which is likely to attract a large number of birds into an area within 13 kilometres radius of the aerodrome and which may pose a risk to aircraft as a result of a bird strike. 7 The IAA has published Aeronautical Services Advisory Memorandum (ASAM No.014) Guidance Material on Aerodrome (ICAO) Annex 14 Surfaces which contains a complete description of the surfaces as well as the ICAO coding 8 for aerodrome runways. 3.2 Safeguarding Technical Facilities The aerodrome licensees for non-state aerodromes own and operate technical facilities located at their aerodromes for aircraft navigation and the provision of air traffic control and/or flight information service to aircraft arriving at, departing from or operating in the vicinity of their aerodromes. They are certificated by the IAA for the provision of these services in accordance with European and national requirements and have responsibility for the safe operation of the technical facilities used in the provision of such services. Consequently, when putting arrangements in place for aerodrome safeguarding, care must be taken to ensure associated technical facilities are also safeguarded. Whereas the IAA is not an aerodrome licensee, it owns and operates CNS facilities at Cork, Dublin and Shannon aerodromes and at various locations throughout the State to support the provision of air navigation services at these airports and in all of the airspace assigned to Ireland except where, by arrangement, these services are provided by other certificated air navigation services providers as outlined in paragraph 1.4 above. The aerodrome licensee, the local air navigation service provider and the IAA are best placed to provide information with regard to their technical facilities which may be located near proposed developments and should be consulted in such cases. 7 Guidance on Land Use and Environmental Control in the vicinity of an aerodrome is contained in ICAO s Airport Planning Manual Part 2, Doc 9184 AN/902 8 Code 1 runways are less than 800 metres long, Code 2 runways are metres long, Code 3 runways are metres long and Code 4 Runways are 1800 metres or more in length.

22 20 AVIATION AND CONSTRUCTION CO-EXISTING - Land Use Planning and Offshore Development 3.3 The IAA Safeguarding Process Note: The process described below addresses structures from the aspect of interference with technical facilities only. In the case of wind turbines, the process is supplemented by the application of additional criteria as described in paragraph 5.1. The assessment of structures as obstacles to aircraft in flight is a separate activity. The IAA applies a two-step process for the consideration of proposed developments that may adversely affect its CNS facilities (see Fig 3.1). The process is based upon the application of ICAO document ICAO EUR DOC European Guidance Material on Managing Building Restricted Areas (BRA) 10. This guidance material is targeted primarily at buildings which may be obstacles but other objects, mobile or stationary, temporary or permanent which may interfere with CNS facilities are also included. Permanent structures with rotational elements (wind turbines) are also addressed. If the IAA considers that the subject of a planning proposal/planning query does not infringe the BRA surfaces as described in ICAO EUR DOC 015, the planning authority is advised that the IAA has no objection to the proposal from the point of view of interference with its technical facilities. Where the IAA considers that BRA surfaces are infringed then the IAA will advise that further expert engineering analysis is required. This analysis is the responsibility of the planning applicant or developer. It remains the responsibility of the planning applicant or developer to provide the IAA with assurance evidence that any proposed development with or without mitigations will not cause unacceptable interference to, or adversely affect any Communication, Navigation or Surveillance facilities under the IAA s control. The impact of obstructions on newly emerging aviation technology has not been fully researched and the safeguarding process applied by the IAA may be adjusted in any particular case as its sees fit. It is important to note that this process only covers assessment of developments for interference with the IAA s CNS facilities. Assessment as an obstacle to aircraft in flight is a complimentary activity conducted by aerodrome, airspace and flight procedures personnel within the IAA. Similarly, other ANSPs and/or aerodrome operators will have processes for assessing developments from a CNS, flight procedures, and aerodrome safeguarding perspective. Military aviation falls outside the IAA s safeguarding responsibility. Consequently an assessment of the impact of a proposed development on military aviation, as an obstacle to aircraft or from the perspective of technical interference with military CNS facilities, requires consultation with the Department of Defence. 9 ICAO EUR Doc 015 Second Edition 2009 proposes harmonised protection zones for CNS facilities within which all building activities should be assessed and a process for the conduct of such assessment. 10 A Building Restricted Area is defined as a volume where buildings have the potential to cause unacceptable interference to the signal-in-space in the service volume of CNS facilities. All such facilities have BRA defined which is not limited to actual site boundaries of the facility but extend significant distances from the facility.

23 Irish Aviation Authority Policy - Version 1: 10 December IAA Two Step Process for Safeguarding CNS Facilities STEP 1 Developer submits development proposal pre-planning query to Planning Authority Where it is identified that a proposal may adversely impact upon IAA facilities then IAA is consulted Does proposal infringe BRA surfaces NO YES STEP 2 IAA requires Specialist Engineering analysis to be carried out by planning applicant IAA experts review Assurance evidence provided by applicant Acceptable interference to facility performance YES NO IAA Raise planning objection No planning objection Fig 3.1: IAA Two Step Process

24 22 AVIATION AND CONSTRUCTION CO-EXISTING - Land Use Planning and Offshore Development Step 1 1. Planning application/pre-planning query is made. The planning authority passes this to the IAA Corporate Affairs Department for review. 2. IAA Corporate Affairs Department submits the application to the appropriate engineering experts within IAA for initial analysis. 3. If the appropriate engineering experts consider that the planning proposal does not infringe the BRA surfaces as described in ICAO EUR DOC 015, the Corporate Affairs Department of the IAA is advised that the appropriate engineering experts have no objections to the proposal from a CNS interference perspective and Step 2 is not proceeded with. Step 2 1. If the appropriate engineering experts consider that BRA surfaces are infringed, the appropriate engineering experts within the IAA will advise the Corporate Affairs Department that further expert engineering analysis is required. This analysis is the responsibility of the developer. The IAA can provide information on organisations with the necessary competence to undertake such analysis. 2. If expert analysis demonstrates that the interference effects are within acceptable limits as decided by the appropriate IAA engineering experts (following a review of evidence provided), the planning authority is advised that the IAA has no objection to the application from a technical interference aspect. 3. If the analysis shows that the interference exceeds acceptable limits, the planning authority is advised that the IAA will object and outline the basis for the objection. 4. Following rejection of a building proposal it may be possible to modify and re-submit the planning proposal. A modified proposal will be subjected to the full review processes as described above. It is a requirement that the following types of construction/ building shall be assessed even when outside the areas defined as restricted areas in ICAO EUR DOC 015: Wind Turbine Generator (Excluding Microwind turbines; Skyscrapers; Large excavation works; TV towers; Other High Towers.

25 Irish Aviation Authority Policy - Version 1: 10 December It should be noted that the use of any large construction equipment (tower cranes etc.) used during the construction of any building must also be assessed. This is because while the final proposed development may not impinge a restricted area the equipment used to construct or develop the building may so do. The IAA procedure applies to the following facilities/systems: 1. Distance Measuring Equipment (DME) 2. VHF Omni Range (VOR/DVOR) 3. Direction Finder (DF) 4. Non Directional Beacons (NDB) 5. Ground Base Augmentation Systems 6. Instrument Landing Systems (Localiser, Glide- Path & Markers, LDMEs) 7. Satellite Based Augmentation Systems (Ground Monitoring Elements) 8. VHF Communications 9. Primary Surveillance Radar 10. Secondary Surveillance Radar 11. Ground based Automatic Dependant Surveillance Broadcast (ADS-B) and Surface Movement Radar (SMR). The IAA procedure does not apply to the following facilities/systems which must be considered on a case by case basis. 1. Obstacle restrictions that are given in ICAO EUR DOC 015 do not cover the effect of proposed buildings on aircraft operating under Visual Flight Rules or Instrument Flight Rules. The criteria for evaluating these is given in ICAO Annex 14 (Aerodromes) and in ICAO DOC 8168(PANS OPS) Degradation of Signal in Space Caused by Electromagnetic Interference (EMI) 3. Satellite up/down links 4. VHF/UHF Ground/Ground Communications 5. Microwave Links 6. High Frequency Communication Facilities 7. Critical and Sensitive Areas based on Guidance covered in ICAO ANNEX 10 (Aeronautical Communications) 8. Monitoring Sites and Radio Links 9. Precision Approach Radar (PAR) Facilities 10. Military Communication Facilities 11. Microwave Landing Systems 12. Global Navigation Satellite Systems AIP Ireland section ENR 4.1 contains a list of Radio Navigation Aids/Systems for the en-route area. Information on Navigation Aids at airports in contained section AD ICAO PANS-OPS, (Doc 8168), Procedures for Air Navigation Services Aircraft Operations Volume I - Flight Procedures & Volume II- Construction of Visual and Instrument Flight Procedures.

26 24 AVIATION AND CONSTRUCTION CO-EXISTING - Land Use Planning and Offshore Development Safeguarding is described as a process of checking proposed developments/constructions in order to protect: portions of airspace through which aircraft fly in the vicinity of an aerodrome; the integrity of radar and other electronic facilities by preventing unacceptable interference; visual aids, such as approach and runway lights, by preventing them from being obscured or confused with other lights; aircraft from the risk of bird strike or other wildlife strike by preventing an increase such activity in the vicinity of an aerodrome.

27 Irish Aviation Authority Policy - Version 1: 10 December : WIND TURBINES 4.1 Land Based Wind Turbines/Farms Wind energy and aviation are important to Ireland s national interests and both industries have legitimate ambitions that must be carefully balanced. Therefore it is important that the aviation community recognises the Government s policy for wind turbine/farm developments to play an increasing role in the national economy and ensuring Ireland achieves binding EU 2020 targets for renewable energy and emissions reduction. As such, the aviation community must engage positively in the process of developing solutions and ensuring productive cooperation between wind energy and aviation operations. Similarly, wind turbine/farm developers must understand the potential impact of developments on aviation, both at a local and a national level, and fully engage with the aviation industry to develop suitable mitigation solutions for problem areas. Ireland s wind energy and aviation industries have co-existed and cooperated for 20 years with a good track record in aviation safety. As activity increases and technology develops in both areas it is expected that this policy document and the software system (ASSET) described in Chapter 7.0 will contribute to continued productive cooperation. This Chapter provides a summary of the issues that aviation stakeholders and developers should consider when assessing the impact of a proposed wind turbine/farm development. It is not intended to be exhaustive because local circumstances may raise issues that are unique to a specific case. For this reason, the local aerodrome operator, air navigation service provider and air traffic control unit are best qualified to provide expert interpretation of what the impact will be and how it will affect the safety, efficiency and flexibility of their operations and the operation of aircraft. The development of wind turbines/farms has the potential to impact aviation in some of the following ways: 1. Physical obstructions. The closer a wind turbine is to an airport, radar station (sensor) or navigation or communication facility, and while within the line of sight (LOS) of the transmitting antennae, the greater the negative effect on the facility is likely to be. 2. The generation of false radar returns (clutter) on Primary Surveillance Radar (PSR) or false targets caused by signal reflections on Secondary Surveillance Radar (SSR). These, associated with other negative consequences such as shadow regions 12 may interfere with the safe provision of air traffic control or flight information services. 12 The presence of a physical obstruction in the path of a radar beam creates a region behind the obstruction within which aircraft would be masked from detection. This is known as the shadow region.

28 26 AVIATION AND CONSTRUCTION CO-EXISTING - Land Use Planning and Offshore Development 3. Electromagnetic interference with and adverse effects on the overall performance of communication, navigation and surveillance equipment. A wide range of systems used by aircraft to navigate and by air traffic controllers to provide separation between them, together with air-ground communications facilities, can be affected by wind turbine developments. Wind turbines can interfere with the radiated signal from these systems because of their physical characteristics such as their situation and orientation in relation to the facility. As a result, the integrity and performance of the systems can be degraded and introduce safety hazards to the services they provide. 4. Turbulence caused by the wake of the turbine which extends stream-wise for a considerable distance behind the blades and the turbine tower. The dissipation of the wake intensity depends on the convection, the turbulence diffusion and local topography (terrain, obstacles etc.). Published research shows measurements at 16 rotor diameters downstream of the wind turbine indicating that turbulence effects are still noticeable. Smaller type aircraft, helicopters, hot air balloons and parachuting activity are particularly susceptible to this turbulence and pilots who experience it are encouraged to file a report via their applicable safety occurrence reporting scheme. In extreme cases turbulence can cause loss of aircraft control from which it is impossible to recover. 5. The creation of choke points in uncontrolled airspace where aircraft operating under visual flight rules are forced into a reduced volume of airspace and must maintain separation between themselves. 6. A detrimental effect on the environment caused by increased fuel burn, CO2 emissions, and possible noise pollution where aircraft are obliged to fly extended routes to avoid wind farms. This of course is balanced against emissions which would have been released by the average power generation mix. Clearly, large commercial turbines have the greatest impact on aviation, but the installation of other equipment may also affect the operation of aircraft, the provision of CNS services and air traffic control. Smaller turbines, and the preliminary activities for larger turbines such as the erection of anemometer masts (see paragraph 4.4) on potential development sites can impact aviation and therefore require assessment. Erecting cranes, albeit temporary obstacles, may be higher than the structure being constructed and must be considered as an obstacle when considering the development in question.

29 Irish Aviation Authority Policy - Version 1: 10 December Offshore Wind Turbines/Farms Offshore wind farms, which can present the same negative effects to aviation as those on land, are excluded from the provisions of the Planning & Development Act 2000 but are subject to the Foreshore Act 1933 (as amended) which is administered by the Foreshore Section of Department of the Environment, Community & Local Government. The Department is responsible for issuing consents (the equivalent of planning permissions), in the form of lease 13 arrangements, for of construction of offshore wind turbines/farms. The foreshore is defined in Irish legislation as the bed and shore, below the line of high water of ordinary or medium tides, of the sea and of every tidal river and tidal estuary and of every channel, creek, and bay of the sea or of any such river or estuary, out to a limit of twelve nautical miles ( kilometres) from the low-water mark. The outer limit of the foreshore is coterminous with the seaward limit of the State s territorial waters. Following a lengthy period of consultation, a General Scheme of the Maritime Area and (Foreshore) Amendment Bill was published in October 2013 and is expected to be enacted during The Bill will have three main aims: to align the foreshore consent system with the planning system; to provide for a single Environmental Impact Assessment for projects; and to provide a coherent mechanism to facilitate and manage development in the exclusive economic zone (EEZ) and on the continental shelf, including offshore renewable energy projects. It is proposed to define in law an Irish maritime area, which would encompass the foreshore, EEZ and the continental shelf. From an aviation perspective, the rules of the air require that the minimum aircraft height when operating over the sea is 500 feet. There may, however, be inaccuracies associated with aircraft altimetry. An aircraft attempting to fly 500 feet above the sea may, in certain circumstances, inadvertently be lower than 500 feet above mean sea level. Search and rescue activity is exempted from the specified minimum height and flight visibility requirements and can be anticipated to operate at 500 feet or lower levels in adverse weather conditions for the purpose of saving life. Helicopters supporting explorations rigs, vessels, lighthouses and offshore production platforms would not be subject to the above minimum height requirement while landing or taking off in accordance with normal aviation practice. Additionally, the operating minima applicable to civil aircraft do not apply to military aircraft which may frequently operate below 500 feet over the sea. The IAA has published Aeronautical Services Advisory Memorandum (ASAM No. 18) Guidance Material on Off-Shore Wind Farms setting out certain minimum requirements for the lighting, marking, radar enhancing and supply of information for promulgation to ensure the conspicuity of off-shore wind turbines/farms and associated structures. 13 A Lease is generally issued for a development that requires exclusive occupation of the foreshore. Developments requiring a lease include offshore wind farms.

30 28 AVIATION AND CONSTRUCTION CO-EXISTING - Land Use Planning and Offshore Development 4.3 The Cumulative Effect While developments with small numbers of wind turbines can have an adverse effect on aviation operations, it is the proliferation of developments and the cumulative impact that is of more significant concern to aviation. It may be possible to successfully mitigate the effects of a single turbine or small development of turbines. The combined effect of numerous individual turbines or multiple wind turbine developments may be more difficult to mitigate and the addition of wind turbines to an existing wind farm will require an assessment of the totality of the development. The cumulative effect of geographically separated wind turbine developments may have more impact on aviation than if such developments were located in close proximity to each other. For example, individual areas of radar clutter separated by five nautical miles could have more impact on the provision of air traffic control than one slightly larger area of clutter. This does not mean to suggest that large areas of clutter are always preferable; however, this should be taken into consideration in discussions between the developer and aviation parties. The basis for an objection based on cumulative effect is likely to be that the safety and efficiency of the aerodrome or air navigation service may not be maintained or that the growth of an aerodrome or air navigation service may be constrained. The decision concerning how firm these future plans have to be in order to be considered is within the remit of the planning authority. In any event, operators are encouraged to produce safeguarding maps indicating their future development plans as these may be taken into consideration by a planning authority when assessing a planning proposal. It is recognised that from time to time potential developments fail to reach maturity within the formal planning stage. Nevertheless, it is in the interests of aviation stakeholders to take account of all developments of which they are aware until they have been formally notified that a proposal is not proceeding. Similarly, it is in the interest of a wind turbine developer to inform all involved parties when such developments do not proceed or are deferred. For aerodrome operators or air navigation service providers there may be a difficulty in protecting aviation activity from these cumulative effects because planning applications are generally dealt with on a first come, first served basis. All approved applications must be taken into account when considering future applications irrespective of the likelihood of a suitable technological mitigation being identified to enable aviation objections to be removed. This could lead to a situation whereby more viable applications are objected to on the grounds of cumulative effect as a result of less viable projects that have been previously approved.

31 Irish Aviation Authority Policy - Version 1: 10 December Developments Exempted Under Planning Regulations S.I. No. 235 (Planning and Development Regulations) 2008 amended the 2001 Regulations (S.I. No. 600 of 2001) to provide for exemptions in respect of renewable technologies for certain types of developments subject to certain conditions and limitations. From an aviation perspective two types of exempted developments are considered here for guidance purposes only. S.I. 235 of 2008 should be consulted for the complete suite of Regulations including conditions and limitations not included below. 1. The erection of a mast for mapping meteorological conditions. (normally a mast which hosts a wind measuring device such as an anemometer and is usually associated with a wind turbine development). The following conditions and limitations apply to this type of construction: a) No such mast shall be erected for a period exceeding 15 months in any 24 month period; b) The total mast height shall not exceed 80 metres; b) The rotor diameter shall not exceed 8 metres; c) Not more than one turbine shall be erected within the site or agricultural holding. The following conditions and limitations apply to both 1 and 2 above: a) The turbine or mast shall not be located within 5 kilometres of the nearest airport or aerodrome, or any communication, navigation and surveillance facilities designated by the Irish Aviation Authority save with the consent in writing of the Authority and compliance with any condition relating to the provision of aviation obstacle warning lighting; b) All turbine or mast components shall have a matt, non-reflective finish and the blade shall be made of material that does not deflect telecommunication signals. It is important to note that an exemption from planning requirements does not relieve a person from his/her obligation to comply with aviation legislation. In this respect a proposal to erect a mast for mapping meteorological conditions which exceeds the height parameters set out in S.I 215 of 2005 (Obstacles to Aircraft in Flight Order) must be notified to the IAA in advance (See Chapter 2 Obstacles to Aircraft in Flight). c) Not more than one such mast shall be erected within the site; 2. The construction, erection or placing of a wind turbine within the site of an industrial building, light industrial building, business premises or agricultural holding. The following conditions and limitations apply to this type of construction: a) The total height of the turbine shall not exceed 20 metres;

32 30 AVIATION AND CONSTRUCTION CO-EXISTING - Land Use Planning and Offshore Development The Irish Aviation Authority operates and maintains a network of state of the art Surveillance Systems at strategic locations throughout the State to support the provision of air traffic control to aircraft.

33 Irish Aviation Authority Policy - Version 1: 10 December : SAFEGUARDING SURVEILLANCE SYSTEMS FROM WIND FARM EFFECT 5.1 The IAA Process for Safeguarding Radar Systems IAA utilises guidance material prepared by The European Organisation for the Safety of Air Navigation (EUROCONTROL) titled How to Assess the Potential Impact of Wind Turbines on Surveillance Sensors. Extracts are reproduced below. The assessment methodology for Primary Surveillance Radar (PSR) and Secondary Surveillance Radar (SSR) is based upon the following zone arrangements: Zone 1: Safeguarding Zone (PSR and SSR). An initial restrictive or safeguarding region that surrounds the surveillance sensor. No developments shall be agreed to within this area (500metres). Zone 2: Detailed Assessment Zone (PSR and SSR). Following the safeguarded region is an area where surveillance data providers would reject planning applications unless they were supported by a detailed technical assessment provided by the applicant and the results of which are found to be acceptable to the surveillance provider. Zone 3: Simple Assessment Zone (PSR only). Beyond the detailed assessment zone is a region within which a simple assessment of PSR performance should be sufficient to enable the surveillance data provider to assess the application. Zone 4: Accepted Zone (PSR 15km and SSR 16km). Beyond the simple assessment zone are areas within which no assessments may be required and within which air navigation service providers would be unlikely to raise objections to wind farms on the basis of impact on surveillance services.

34 32 AVIATION AND CONSTRUCTION CO-EXISTING - Land Use Planning and Offshore Development 5.2 Safeguarding Zones for Radar Systems 2 x antenna horizontal 3 db beam-width Zone 1 Safeguarding 0-500m Far-field monitor Zone 2 Detailed Assessment Zone 3 Simple Assessment Zone 4 No Assessment 500m - 15km and in radar line of sight Further than 15km and in radar line of sight Not in radar line of sight Safeguarding zone Table 5.1: PSR Zone Arrangements Radar Zone 1 Safeguarding 0-500m Fig 5.1: Sector Beam Zone 2 Detailed Assessment Zone 4 No Assessment 500m - 16km and in radar line of sight Further than 16km or not in radar line of sight Table 5.2: SSR Zone Arrangements Additionally Wind turbines shall not be built in a sector of 2 times the radar antenna horizontal beam-width at 3dB, centred on the far-field monitor 14 azimuth and limited up to the range of the far-field monitor. The radar antenna horizontal beam-width at 3dB of all IAA SSR radars is 2.4o ± 0.25o, hence the safeguarding sector beam width is 5.3º. (See Figure 5.1). This is applicable to far-field monitors of primary or secondary surveillance radar. Notwithstanding the use of the EUROCONTROL guidance material, the IAA retains the right to assess any wind turbines/farms even when located outside of Zone 4 and in doing so may take account of such issues as: 1. Obstacles to aircraft in flight, electromagnetic interference and turbulence effect; 2. The safety impact of choke points created as a result of aircraft routing to avoid the constructions; 3. Environmental impact caused by increased fuel burn, CO2 emissions, and possible noise pollution where aircraft are obliged to fly extended routes around the constructions. 14 Far-field monitors are self-contained ground-based units located remotely from the primary or secondary radar sites to provide test targets of known range and azimuth for checking the integrity of the radar data in real-time.

35 Irish Aviation Authority Policy - Version 1: 10 December As of 2014 there are more than 180 wind farms in the State with an installed capacity in excess of 2260 megawatts. Image IWEA

36 34 AVIATION AND CONSTRUCTION CO-EXISTING - Land Use Planning and Offshore Development 6: AERONAUTICAL DATA 6.1 Aeronautical Data Quality Requirements The IAA implements and, where appropriate, supervises the implementation of Commission Regulation (EU) No 73/2010 of 26 January 2010 which lays down requirements for the quality of aeronautical data and aeronautical information for the European Air Traffic Management Network (EATMN) 15. Aeronautical data and aeronautical information falling within the scope of the Regulation includes: 1. The integrated aeronautical information package 16, with the exception of circulars; 2. Electronic obstacle data, or elements thereof; 3. Electronic terrain data, or elements thereof; 4. Aerodrome mapping data. The Regulation applies to the European air traffic management systems, their constituents and associated procedures involved in the origination, production, storage, handling, processing, transfer and distribution of aeronautical data and aeronautical information. It does not cover military operations and training. 6.2 Transfer of Aeronautical Data Air navigation service providers, operators of aerodromes and heliports (for which Instrument Flight Rules procedures and Special Visual Flight Rules procedures have been established) and public or private entities providing aeronautical data or services are required to transfer the aeronautical data and aeronautical information between themselves by direct electronic connection. Aeronautical information service providers must ensure that all aeronautical data and aeronautical information within the AIPs, AIP amendments and AIP supplements is provided in accordance with the publication requirements identified in the relevant ICAO standards. Traceability must be maintained on each data item during its period of validity and for at least 5 years following the end of that period. 15 The EATMN is made up of systems and procedures for airspace management, air traffic flow management, air traffic services, communications, navigation, surveillance, aeronautical information services and for the use of meteorological information. 16 The Integrated Aeronautical Information Package comprises comprises the current Aeronautical Information Publication (AIP), AIP Supplements and Aeronautical Information Circulars (AIC).

37 Irish Aviation Authority Policy - Version 1: 10 December Data Exchange Requirements Annex II to Regulation 73/2010 defines a number of detailed requirements regarding: 1. The aeronautical data set to be exchanged; 2. Data exchange format; 3. Data quality and evidence; 4. Data origination; 5. Data process; 6. Data protection; 7. Formal arrangements for the exchange of aeronautical data; 8. Error reporting, feedback and rectification mechanisms; 9. Tools and software used to support the origination, production, storage, handling, processing and transfer of aeronautical data. Entities involved in the provision of aeronautical information data and services are required to implement and maintain a quality management system (QMS) covering their aeronautical data and aeronautical information provision activities. Such QMS must define procedures to meet the safety and security management objectives defined at annex to the Regulation. Air navigation service providers, operators of aerodromes and heliports and public or private entities providing aeronautical data or services must ensure that any changes to the existing systems listed in the scope outlined in 6.1 above or the introduction of new systems are preceded by a safety assessment, including hazard identification, risk assessment and mitigation. 6.4 Electronic Terrain and Obstacle Data (e-tod) Knowledge of terrain and obstacles is a mandatory requirement for ensuring safety when evaluating a new structure to be built or altered in the State s airspace. Increased economic development frequently involves additional infrastructure, in particular construction of buildings, towers etc., which may impinge into navigable airspace. Due to their implications for air traffic control and the safety of aircraft operations, it is crucial to continuously update information about these obstacles as well as to critically assess and review them. The IAA maintains an obstacle database which is, in effect, a digital representation of the obstacles which includes the horizontal and vertical extent of man-made and natural significant features. In the context of e-tod, obstacles are defined as: All fixed (whether temporary or permanent) and mobile objects, or parts thereof, that a) are located on an area intended for the surface movement of aircraft; or b) extend above a defined surface intended to protect aircraft in flight; or c) stand outside those defined surfaces and that have been assessed as being a hazard to air navigation.

38 36 AVIATION AND CONSTRUCTION CO-EXISTING - Land Use Planning and Offshore Development 6.5 e-tod Areas The IAA is required to ensure the availability of electronic Terrain and Obstacle Data, in accordance with stringent numerical requirements established for four distinct Areas of the State s territory. These areas are: Area 1: The entire territory of a State for obstacles greater than 100 metres in height; Area 2: Terminal control area (or limited to a 45-kilometre radius whichever is smaller), subdivided in 4 smaller sections; Area 3: Aerodrome/heliport area: area that extends from the edges of the runway to 90 metres from the runway centerline and for all other parts of aerodrome/heliport movement areas, 50 meters from the edges of the defined areas; Area 4: Category II or III operations area (restricted to those runways intended for Category II or III precision approaches): the width of the area is 60 metres on either side of the extended runway centerline while the length is 900 metres from the runway threshold measured along the extended runway centerline.

39 Irish Aviation Authority Policy - Version 1: 10 December Present and future aircraft navigation and air traffic control systems depend on high-quality aeronautical data which corresponds to a data product with a maximum of one error in one million units.

40 38 AVIATION AND CONSTRUCTION CO-EXISTING - Land Use Planning and Offshore Development 7: THE AERONAUTICAL SURFACES SCREENING EVALUATION TOOL (ASSET) 7.1 What ASSET Does The IAA has put into service its new web based application known as the Aeronautical Surfaces Screening Evaluation Tool (ASSET). This software system provides the IAA with the facility to meet several of its aviation requirements, one of which relates to storage and publication of electronic data for obstacles, terrain, navigation aids, aerodromes and associated airspace surfaces in accordance with Commission Regulation (EU) No 73/2010 as outlined in paragraph 6.1. ASSET is a one stop shop cloud based solution which allows users to securely input data via the web and ensures complete data traceability back to the originator. In addition, ASSET has advanced capabilities, including two-dimensional (2D) and threedimensional (3D) visualisation and multi-layer functionality which facilitate the assessment of a proposed development from an aviation obstacle perspective. It is user friendly and once data related to a proposed development is entered, it will provide an initial indication as to whether it penetrates protected surfaces or is likely to affect CNS systems. ASSET can be used free of charge by developers, builders, aerodrome operators, air navigation service providers, aircraft operators, planning authorities, government departments, their agencies and any other stakeholder with an interest in the subject area, saving time and resources by providing valuable information on the potential impact on aviation safety of any proposed development or construction, temporary or permanent, in the State. Developers are encouraged to engage with the IAA and/or other aviation stakeholders at the pre-planning stage of any proposed development in respect of which ASSET has indicated that navigable airspace or CNS facilities may be affected. ASSET can support the conduct of an initial assessment by the aerodrome licensee or air navigation service provider. Planning Applications for structures considered en-route (e-tod Area 1) obstacles will be commented on by the Irish Aviation Authority. 1. To ensure that all that planning applications are dealt with in a professional and consistent manner; 2. To ensure that aerodrome licensees have procedures for safeguarding their aerodromes; 3. To forward appropriate details of en-route (e-tod area 1) obstacles to the IAA; 4. To forward appropriate details of applications in the vicinity of licensed aerodromes to the aerodrome licensee; 5. To ensure that an appropriate response is provided to planning authorities/planning applicants in relation to planning applications referred to, or sought by, the IAA. All application for planning permission within the State which may endanger, interfere with the safety of, or the safe and efficient navigation of aircraft should be entered into the IAA s web based system.

41 Irish Aviation Authority Policy - Version 1: 10 December ASSET E-FILING To facilitate an assessment from an aviation perspective, E-FILING is the quickest method for submitting a planning application, request for construction or alteration in respect of temporary and/or permanent structures located on or outside of airport property. Planning applications or queries, regardless of source, should be entered into ASSET by following the steps below: 1. Click New User Registration and complete. Make note of your user id and password; 2. Add Sponsor. This is the party ultimately responsible for the permanent or temporary structure; 3. Click Add New Case ; 4. Proceed with adding your new case. All areas with asterisks must be completed; 5. Click on Verify Map. Verify that the location AND site elevation are correct for your structure and click on the verification Statement; 6. Click on Terms and conditions and Save ; 7. Remember to check the website at least weekly to monitor the status of My Cases ; 8. For further assistance, refer to the User Guide when logged on or call the Support Desk at (0) ASSET Process for Reviewing Planning Applications Currently, the IAA provides input to all formal planning applications referred to it as follows: 1. Use of the ASSET to identify aviation stakeholders that would potentially be affected; 2. Consideration of regulatory requirements; 3. Consideration of whether all other known aviation issues have been taken into account (including other potential developments); 4. Consideration of the appropriateness of comments or statements provided by aviation stakeholders in respect of any aviation based objections. From time to time the IAA is approached for expert aviation advice or opinion concerning the validity of objections to a planning application or the suitability of mitigations proposed. However, it is incumbent upon a developer to liaise with the appropriate aviation stakeholder to discuss and hopefully resolve or mitigate aviation related concerns without requiring further IAA input. However, if these discussions are unsuccessful or an impasse is reached, the IAA can be asked to provide objective comment. It must be remembered that the IAA has no powers to prevent developments going ahead, or to require that an aviation stakeholder remove their objection. ASSET provides 2D and 3D modeling to substantially facilitate the assessment of proposed constructions from an aviation impact perspective.

42 40 AVIATION AND CONSTRUCTION CO-EXISTING - Land Use Planning and Offshore Development 8: STAKEHOLDER COMMUNICATION 8.1 Achieving the Desired Result From the foregoing it can be seen that the construction, wind energy and aviation industries must co-exist. This document is aimed primarily at providing assistance to all stakeholders in understanding and addressing areas of common interest, thereby ensuring greater consistency in the consideration of the potential negative impact of man-made developments on aviation safety. It outlines IAA policy on a range of issues associated with man-made obstacles and their effect on aviation that will need to be considered by aviation stakeholders, construction organisations, land developers, wind energy developers and planning authorities when assessing the viability of proposed developments in the State and, where a conflicts are identified, finding solutions and mitigations satisfactory to each entity. Further information on this Policy Document may be obtained from: Corporate Affairs Department Irish Aviation Authority The Times Building D Olier Street Dublin 2 Note: This document supersedes and replaces the IAA publication Irish Aviation Authority Air Navigation Services Policy on Consultation by Planning Authorities in Relation to Protection of ATM Systems & Facilities from Buildings in or close to Restricted Areas Version 1.0, dated 16th November 2007, 1st Edition. The statutory remit of the planning authorities, and in the case of off-shore developments, the Foreshore section of the Department of the Environment, Community and Local Government, is well understood and it is not the intention of this document to provide instruction on the need or means to object to proposed developments. This decision rests with individual aerodrome operators, air navigation service providers and other aviation or non-aviation stakeholders as they see fit. Furthermore, it should be noted that within the framework of this document, specific issues will have to be addressed on a case-by-case basis, as it is not possible to prescribe a standard solution or mitigation for all situations where a conflict between development and aviation arises.

43 The Irish Aviation Authority believes a collaborative, proactive and consultative approach will ensure the expectations of all stakeholders can be met and ASSET is a key enabler in this regard.

Consideration will be given to other methods of compliance which may be presented to the Authority.

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