15 AVIATION & AIR SAFEGUARDING

Transcription

1 Knockskae Wind Farm Environmental Statement Volume 2 Main Report AVIATION & AIR SAFEGUARDING 15.1 Introduction This Chapter has been prepared by (Osprey), a technical consultancy providing aviation expertise to the wind industry. It identifies and assesses the potential effects that the Knockskae Wind Farm (the Development) may have on civilian and military aviation and air safeguarding in the study area and, if required, the mitigation measures to be implemented to prevent, reduce or offset any potential adverse effects where possible The potential impacts of wind turbines on aviation interests have been widely publicised. There are two dominant scenarios: Physical obstruction: turbines can present a physical obstruction at, or close to, an aerodrome or other aviation activity site; and Radar / Air Traffic Services: turbine clutter appearing on a radar display can affect the safe provision of air traffic services (ATS) as it can mask unidentified aircraft from the air traffic controller and / or prevent him from accurately identifying aircraft under his control. In some cases, radar reflections from the turbines can affect the performance of the radar itself Methods Scope of Assessment This Chapter presents a summary of the results of an Aviation Impact Assessment (AIA) undertaken by Osprey, on behalf of (the Applicant). The AIA identifies potential effects on aviation stakeholders in the area of the Development and provides an objective assessment of the effects and any necessary mitigation measures Osprey considered the potential for the Development to have an effect on the aviation interests, either in terms of the existing radar infrastructure and / or flight operations, of the National Air Traffic Services (NATS), the Ministry of Defence (MOD), and regional airport operations at Glasgow Prestwick (Prestwick) Airport. There are no other affected aviation stakeholders ) 1 tool to model the terrain elevation profile between the identified Primary Surveillance Radars (PSR) and wind turbine positions within the Site boundary, to provide a graphical representation of the intervening terrain and theoretical direct Line of Sight (LOS), in order to determine the effected radar systems within the baseline. This Chapter summarises the results of a detailed AIA completed by Osprey in 2013 and updated in 2014, which is contained in full in the Technical Appendix 15.1 (Osprey, 2014). Assessment Guidance The Aviation Industry and the provision of Air Navigation Services are regulated through extensive legislation, with the mechanism for wind development enabled through the consenting system and in accordance with regulatory guidance. The following policy and guidance documents were considered during the baseline definition and assessment activities: CAP 393 Air Navigation: The Order and the Regulations (known as the Air Navigation Order (ANO) (CAA, 2014 (a)); CAP 764: Civil Aviation Authority, Policy and Guidance on Wind Turbines (CAA, 2013 (a)); and Renewable UK Guidance on Low Flying Activity and Onshore Tall Structures Including Anemometer Masts and Wind Turbines (RenewableUK, 2012) Other data sources and guidance considered under desktop review of the definition of the baseline environment include the following: CAA Visual Flight Rules Chart (CAA, 2014 (b)); CAA, CAP 32 UK Integrated Aeronautical Information Package (UKIAIP): The UKIAIP is the main resource for information and flight procedures at all licensed UK airports as well as airspace, enroute procedures, charts and other air navigation information (NATS, 2014); and Military Aeronautical Information Publication (Mil AIP): The Mil AIP is the main resource for information and flight procedures at UK Military Aerodromes (MOD, 2014 (a)). Assessment Methods Analysis has been conducted in accordance with Civil Aviation Authority (CAA) Civil Air Publication (CAP) 764, Policy and Guidelines on Wind Turbines (CAA, 2013 (a)). Potential aviation stakeholders were identified and for each receptor, the physical obstruction and / or radar effect, and then subsequently the operational effects were evaluated. The operational effect assessment pays heed to, but is not limited to, consideration of: the orientation of airfield approach and departure routes; physical safeguarding of aircraft operations; and airspace characteristics Radar performance and propagation modelling has been undertaken to determine the theoretical detection of wind turbines by the region s radar infrastructure. Osprey utilised the ATDI ICS LT (Version Approach to the Assessment Potential aviation stakeholders were identified in accordance with the guidance in the CAP 764 (CAA, 2013 (a)), with the suggested anticipated extents of impact utilised as a minimum. The suggested extents are guidelines for the initiation of consultation with the various aviation stakeholders. It should be noted that the distances are a guide and that some operations take place beyond the stated minima. It is acknowledged that objections from beyond the recommended aviation stakeholder consultation distances can potentially be sustainable and valid, and the threshold used for identifying potential aviation stakeholders is not a definitive statement of the extent of potential impacts arising from the Development. 1 Advanced Topographic Development & Images Ltd ICS Lite

2 Knockskae Wind Farm Environmental Statement Volume 2 Main Report Consideration is given to any aviation infrastructure that is within operational range of the Development. al range varies with radar type or operations and therefore the study areas are defined on a case by case basis in this respect The LOS analysis is a limited and theoretical desk based study; in reality there are unpredictable levels of signal diffraction and attenuation within a given radar environment that can influence the probability of a turbine being detected. The analysis is designed to give an indication of the likelihood of the turbine being detected such that the operational significance of the Wind Farm relative to nearby aviation stakeholders can be assessed The analysis contained in the AIA involves a systematic review of the charts and data available through the Mil AIP (MOD, 2014 (a)) and utilisation of CAA Visual Flight Rules charts (CAA, 2014 (b)). The review seeks to identify all potential aviation stakeholders, the location of their operations, procedures relative to the Development and any potential effects associated with the Development. The analysis considers the possible options that could mitigate the impact of the Development on the operations of identified aviation stakeholders. The AIA has been conducted for the proposed eleven 126 metre (m) to tip height wind turbines. A detailed scope and methodology is provided in the full AIA in Appendix 15.1 (Osprey, 2014). Impact Assessment Methodology Sensitivity The sensitivity of a receptor is subjective in aviation terms and therefore difficult to quantify. Whereas an Air Defence Radar installation would be an obvious high value and high sensitivity receptor to most (due to its role in UK national security), the sensitivity of a local aerodrome can also often be rated high if the Planning Authority considers the receptor to be a significant asset to the local area. The identified receptors in this analysis are considered to have a high sensitivity to effects, given their safety critical function. Magnitude The magnitude criterion of the potential effects on aviation and radar receptors is assessed using the method and terminology given in Table Table 15.1 Impact Magnitude Criteria Descriptor/Criteria High Medium Description Receptor unable to continue safe operations or safe provision of air navigation services (radar) in the presence of the wind turbines. Technical and/or operational mitigation of the effect is required. Receptor able to continue safe operations but with some restrictions or nonstandard mitigation measures in place Significance Significance criteria for aviation impacts are typically difficult to establish; they are not strictly based on the sensitivity of the receptor or magnitude of change but on whether the industry regulations for safe obstacle avoidance or radar separation (from radar clutter) can be maintained in the presence of the wind turbines Any anticipated impact upon aviation stakeholders which results in restricted operations is considered to be of significance. assessment of significance. The following approach identified in Table 15.1 is used and summarises the The determined effects have been informed by the results of the desktop assessment and additional consultation with reference to the existing evidence base regarding the effects of wind turbines on aviation. Table 15.1 Significance Assessment Matrix Receptor Sensitivity Impact Magnitude High Medium Low Negligible High Significant Significant Significant Not Significant Medium Significant Significant Not Significant Not Significant Low Significant Not Significant Not Significant Not Significant Negligible Not Significant Not Significant Not Significant Not Significant Summary of Relevant Planning Policy Relevant planning policy: Overarching National Policy Statement (NPS) FOR Energy EN-1 (DECC, 2011). Where the proposed development may have an effect on civil or military aviation and / or other defence assets, an assessment of potential effects should be set out in the Environmental Statement (ES) (paragraph of NPS EN-1). The Applicant should consult the MoD, CAA, NATS and any aerodrome licensed or otherwise likely to be affected by the proposed development in preparing an assessment of the proposal on aviation or other defence interests (paragraph of NPS EN-1). Any assessment of aviation or other defence interests should include potential impacts of the project upon the operation of communications, navigation and surveillance (CNS) infrastructure, flight patterns (both civil and military), other defence assets and aerodrome operational procedures. It should also assess the cumulative effects of the project with other relevant projects in relation to aviation and defence (paragraph of NPS EN-1). Low Negligible Receptor able to continue operations with standard mitigation in place No impact on this receptor

3 Knockskae Wind Farm Environmental Statement Volume 2 Main Report Identified Aviation Stakeholders Glasgow Prestwick Airport Glasgow Prestwick Airport (Prestwick) is an independent airport located approximately 2 kilometres (km) to the northeast of the town of Prestwick, South Ayrshire. The Development is located on a bearing of 180 and a distance of approximately 23.5 km from the Airport The Airport is currently under the administration of the Scottish Government and operated by Glasgow Prestwick Airport Ltd. Prestwick provides regular scheduled national and international flights. The Royal Navy Fleet Air Arm operates three Sea King helicopters from Prestwick, providing Search and Rescue services. In addition, the airport is home to a flying club and flight training operator in addition to aeroclub operations. MOD Low Flying Low flying is a demanding but essential skill for military aircrew, gained through progressive training and continuous practice within the United Kingdom Low Flying System (UKLFS). The ability to operate effectively at low level by day and night is vital to fast jets, transport aircraft and helicopter operations as they support forces on the ground, and hence the UKFLS is a high sensitivity receptor. The Development is located within the UKLFS Low Flying Area (LFA) 16 and within Tactical Training Area (TTA) 20T, when this area is active Height in the UKLFS can be referred to in terms of minimum separation distance (MSD). This is the distance that must be maintained between any part of an aircraft in flight and the ground, the water or any other object. In a LFA, aircraft can operate down to 250 feet (ft) MSD; however, in a TTA fast jets can fly at 100 ft MSD and helicopters can fly down to 100 ft above ground level (agl) or down to ground level, in support of troops on the ground. NATS NATS Ltd provides air traffic services at some airports in the UK and to traffic en-route within UK airspace. NATS operate a number of long range primary and secondary radars positioned to provide maximum coverage of UK airspace. Additionally, military controllers operate at NATS Air Traffic Control Centres, and in conjunction with their civilian counterparts, manage the coordination between civilian and military flights. Surveillance data is also used by other air navigation service providers (ANSPs) such as the MOD and airports. The Development is located on a bearing of 260 at 53.5 km from the Lowther Hill PSR. Kilkerran Airstrip Kilkerran Airstrip is an unlicensed airstrip consisting of a grass runway which is orientated northeastsouthwest and of is of approximately 780 m in length. The Development is located, at its closest point, on a bearing of 115 from the airstrip and at an approximate range of 4.25 km. Summary of Consultation The approach to the assessment has identified those radars or systems and practices, which have the potential to interact with the Development. systems which are considered in the AIA. Table 15.3 Consultation Activity Consultee Summary Response Action Taken Prestwick Airport MOD Low flying Prestwick responded that the Wind Farm would be detectable by their radar system and affect Airport operations (Prestwick Airport, 2014 (a)). The final scoping response from the Airport confirmed the intention to object to the Development. The response also indicated the potential for a cumulative effect on their radar and operations. The MOD was consulted regarding the initial Development parameters, and responded that they had concerns with the Development (MOD, 2014 (b)). The MOD was re-consulted on 1 st September 2014 with the proposed 11 turbine layout. A response was provided on 15th October 2014 which stated that the MOD may have concerns about the proposal due to potential impact on low flying operations. The response stated that it is possible that the MOD will request that the turbines are fitted with visible or infrared aviation safety lighting. NATS NATS consultation response indicated that that the proposed development would not affect NATS radar and communications infrastructure (NATS, 2013), and a further generic guidance response was provided in July 2014 for the then proposed 12 turbine layout (scoping). Kilkerran Airstrip The Kilerran Airstrip was consulted via phone and , through which a map of the site and the then proposed 19 turbine layout was issued. No response was received to date. Error! Reference source not found. highlights those Discussions are in progress regarding the implementation of a technical mitigation solution, but at the present time no solution implementation process has been agreed (Prestwick Airport, 2014 (b)). Discussions are in progress regarding the MOD concerns and the implementation of aviation obstruction lighting to the Development. Osprey analysis concurs with the NATS conclusions (Osprey, 2014). The reduced turbine number is not likely to alter NATS response when the development is submitted for planning approval. Consequently, the potential for the Development to affect NATS radar and operations has been scoped out from further analysis. At over 4 km from the Airstrip, the Development would be well outside the lateral limit of any physical safeguarding criteria for an airfield of this size and intended operation. It is therefore considered that the Development will not directly impact aviation operations at the Airstrip and

4 Knockskae Wind Farm Environmental Statement Volume 2 Main Report Existing Conditions Aviation Baseline Environment is scoped out from further analysis In the UK Flight Information Region (FIR) and Upper Information Region (UIR), airspace is classified as A, C, D, E, F and G in accordance with International Civil Aviation Organisation (ICAO) standards (Note: There is no airspace designated as Class B in UK airspace). Airspace Classes A to E are variants of controlled airspace in which aircraft require an Air Traffic Control (ATC) clearance. Airspace Classes F and G are designated as uncontrolled airspace in which aircraft can operate autonomously without any clearance required The airspace in the vicinity of, and above the Development is categorised as follows: Class G Uncontrolled Airspace up to 5,500 ft above mean sea level (amsl); any aircraft can operate in this area of uncontrolled airspace without a requirement to be in communication with an air traffic service (ATS) Unit. Pilots of aircraft operating Visual Flight Rules (VFR) in Class G airspace are ultimately responsible for seeing and avoiding other aircraft and obstacles; Class D Controlled Airspace (CAS) of the Scottish Terminal Control Area (TMA) from 5,500 ft amsl up to Flight Level (FL) 195 (19,500 ft); aircraft operating within this airspace must be in receipt of an ATS from NATS Prestwick Centre or Prestwick Airport, the air traffic controller is responsible for maintaining typically 5 Nautical Miles (NM) lateral separation between aircraft; and Class C CAS is established above the Scottish TMA (from FL 195); all aircraft operating in this airspace must be in receipt of a civil or military ATS from NATS Prestwick Centre. In addition, the proposed turbines would be located within LFA 16. Furthermore, TTA 20T when active and utilised covers a large area within LFA 16. The Development is within the lateral confines of both LFA 16 and TTA 20T. These areas are located in southern Scotland, which includes the Borders Region, Dumfries and Galloway and other counties up to and including those within the central belt of Scotland. The Royal Navy helicopter base at Prestwick Airport, the QinetiQ range facilities at West Freugh, and the Army training area at Kirkcudbright are also located within the area. Future Baseline It is anticipated that the airspace would continue to be used by the identified aviation stakeholders, and the baseline would remain as currently defined Potential Effects Prestwick Airport The infrastructure required in the process of the construction of the Development would have no significant effect on the Prestwick PSR system. The static nature of the infrastructure is such that it would not be processed and presented onto ATC display screens by the PSR system. No significant effect on radars and operations is expected ahead of the turbines commencing operation Prestwick requires an accurate PSR system to support their provision of ATS to aircraft operating to and from, or requesting a service in the vicinity of, the Airport. The Development would be situated in close proximity to aircraft flight patterns and procedures utilised by aircraft on arrival and departing the Airport Air Traffic Controllers are responsible for maintaining typically 5 NM (9.26 km) lateral separation between aircraft. Where LOS to a PSR exists, turbines would be presented on radar display screens resembling real aircraft targets and could also mask genuine aircraft returns; as such, controllers must maintain 5 NM between aircraft under their control and any radar clutter to ensure flight safety to aircraft operations. The radar may also be de-sensitised by clutter processing within the radar sector containing turbines, potentially resulting in real aircraft targets disappearing from the radar display screen Radar propagation modelling has been undertaken (Osprey, 2014) and the interaction of radar with wind turbines is well understood. At a proposed blade tip height of 126 m, the Development is theoretically likely to cause clutter to be presented onto ATC display screens The magnitude of the potential effect is high and the sensitivity of the receptor is determined to be high; the effect therefore has been assessed as significant Agreed mitigation is required to remain operational until the Development has been fully decommissioned; consequently, this phase would have no significant effect on the Prestwick PSR. Micro-siting No additional effect on this receptor is anticipated should the micro-siting of any individual turbine(s) be required. MOD Low Flying The infrastructure required in the construction process of the Development may present a physical obstruction and effect operations of Military Low Flying aircraft The Development would be located within LFA 16 and when active, within TTA 20T. These areas are considered by the MOD to be of key importance for Military low flying training The airspace in the vicinity of the Development is considered to be of high priority in terms of the UKLFS, indicating an area where the MOD may raise objections to wind developments. During initial consultation, the MOD stated that they had concerns with the Development. Further consultation with regard to the reduced Development parameters has been initiated; however, no response has been received. Consequently, the magnitude of effect is determined to be high and the sensitivity of the receptor is also determined to be high, resulting in the effect being significant.

5 Knockskae Wind Farm Environmental Statement Volume 2 Main Report The infrastructure required in the process of the turbine decommissioning may present a physical obstruction and effect operations of Military Low Flying aircraft. Micro-siting No additional effect on this receptor is anticipated should the micro-siting of any individual turbine(s) be required Mitigation General It is good practice to notify aviation stakeholders of the location and dimension of any wind energy development and the associated construction activities. Information regarding construction should be passed to the Defence Geographic Centre and the General Aviation Awareness Council at least 6 weeks in advance of the erection of the first turbine and to follow up on the day with a confirmation that the activity has taken place. The data should include: Location, height (of all structures over 150 ft agl), date of erection, date of removal and lighting type (none, infra-red or lighting brightness); and RenewableUK should be copied on the submission of all such information as an independent record and that they might share the information with other relevant official agencies. Appropriate information about the construction of the Development and any associated lighting (where applicable), for example the height and temporary location of construction cranes, should be provided to the UK Aeronautical Information Service (NATS AIS) for promulgation throughout the UK IAIP (NATS, 2014). Prestwick Airport As stated at paragraph , the construction phase would have no significant effect on the Prestwick PSR system; therefore, there is no requirement for mitigation Resolution infill technology involves the location of an additional radar sensor to be positioned in proximity to the subject wind farm or can be co-located with the impacted PSR system. The resolution infill sensor must be capable of resolving real aircraft returns from those generated by wind turbines, and subsequently reject the turbine returns as clutter. The candidate resolution infill solutions under development and being marketed for use in the UK are: Aveillant Holographic Radar ; C Speed LightWave Radar; and and could prove to be viable options to mitigate the effect of the Development on the Prestwick Airport PSR Should consent be granted to the Development, with three years to discharge an aviation planning condition, it is considered that, with the collaboration of the Airport, a technically and operationally acceptable solution can be implemented Any agreed mitigation would remain operational until the Development has been fully decommissioned; as such this phase would have no significant effect on the Prestwick PSR system. MOD Low Flying of the Development, including turbines and the assembly infrastructure, may present a physical obstruction to Military Low Flying aircraft. Appropriate details regarding the construction of the Development, for example the height and temporary location of construction cranes, and any associated lighting (where applicable) should be provided to the Defence Geographic Centre (DGC) and UK Aeronautical Information Service (NATS AIS) for promulgation throughout the UK IAIP (NATS, 2014) Pilots of Military Low Flying VFR aircraft are ultimately responsible for their own terrain and obstacle clearance. Pilots refer to aviation charts detailing the relevant terrain and any obstacles; this mapping would depict the location of the Development and its parameters in the event of it being constructed. Details of the Development are required to be promulgated through the DGC and NATS AIS to enable the site s depiction on appropriate aviation charts and documentation as required The requirement for aviation lighting is stipulated for structures which extend greater than 150 m agl. However, the CAA may further support the use of aviation obstruction lighting at the request of an aviation stakeholder for shorter structures, should this be deemed necessary. In their response the MOD stated that it was possible that they would request that the turbines be fitted with infra-red or visible (to the naked eye) aviation obstruction lighting. Consultation with the MOD through the Defence Infrastructure Organisation (DIO) would determine their specific lighting requirements. It is anticipated that this would be controlled by way of a suitably worded planning condition of the Development, including both the turbines and the associated infrastructure, may present a physical obstruction to Military Low Flying aircraft. In order to safeguard the general use of the area by military traffic, the Applicant would adhere to the notification requirements outlined at Paragraph in conjunction with any lighting requirements should this be deemed necessary. Terma Scanter These systems are in their research and development phases and are therefore not available for deployment at present. The systems are making progress toward becoming available for deployment

6 Knockskae Wind Farm Environmental Statement Volume 2 Main Report Residual Effects No significant effect on the Prestwick PSR and operations is expected ahead of the turbines commencing operation. Consequently, the Development would not have a significant residual effect on operations Adherence to the notification requirements outlined in paragraph of this chapter will provide appropriate details of the progress of the construction process for aircraft flight planning purposes The implementation of a suitable technical mitigation solution for the Prestwick PSR system would ensure that the Development would not have a significant residual effect on operations The MOD is considered likely to formally request that the Development be fitted with a form of aviation obstruction lighting. This mitigation is anticipated to be sufficient in terms of the UKLFS, resulting in an insignificant residual effect Any agreed mitigation will be required to remain operational until the Development has been fully decommissioned; as such this phase will have no significant residual effect on Prestwick radar and operations Adherence to the notification requirements outlined in paragraph of this chapter will provide appropriate details of the progress of the construction process for aircraft flight planning purposes Cumulative Effects Scope of Assessment There are a number of operational, consented and proposed wind farms, at various stages in the planning process, within the vicinity of the Development. It is known that Air Navigation Service Providers (ANSPs) have concerns regarding the increasing impact of wind turbines on radar and operations in the region. There are a number of nearby wind energy developments within 20 km of the Development listed below, that may be considered by Prestwick Airport to place an increasing cumulative impact on their operations It is considered likely that some of the sites listed below would be detectable by the Prestwick PSR system and be considered to have the potential to pose a cumulative effect. It must be noted that formal assessment of such potential detectability has not been completed by Osprey. al Hare Hill; Hadyard Hill; and Dersalloch; and Windy Standard Extension. Application Afton; Ashmark; Glenmount; Hare Hill Extension; High Cumnock; Keirs Hill; Knockshinnoch; Linfairn; North Threave; and South Kyle It is considered highly likely that any technical mitigation solution implemented by Prestwick Airport to resolve the effects of the Development on their radar system will have the capability to mitigate other sites that would be detectable by this system Summary The Development is within the operational range of, and is considered to be theoretically detectable by the Glasgow Prestwick Airport radar system. The Development is located in an area that is considered to have an operational significance to Prestwick. The Development is considered not to have an effect on other radar systems or other aviation stakeholders in the region The Applicant will engage with Prestwick Airport to reach a resolution. The implementation of a suitable technical mitigation solution would ensure that the Development would have an insignificant residual effect on the utilisation of the Airport radar system Analysis concludes that the Development is located in an area of High Priority with regard to military Low Flying activities. The requirement of a form of aviation obstruction lighting, if deemed necessary, is expected to provide sufficient mitigation in terms of the UKLFS operations. Appropriate resolution and agreement for any MOD lighting requirement is expected to be determined through formal stakeholder consultation In conclusion, the Applicant acknowledges that the Development will have a potential significant effect on the Prestwick Airport radar system and operations, and on military Low Flying operations in the region. Agreement on the use of the identified mitigation solution options would conclude in the Development having an insignificant residual effect on infrastructure and operations. Some initial consultation has been undertaken with Prestwick Airport and the MOD; however, comprehensive formal consultation will follow. Consented Windy Standard. Ailsa Hospital; Assel Valley;

7 Knockskae Wind Farm Environmental Statement Volume 2 Main Report References CAA. (2013 (a)). CAP CAA Policy and Guidance on Wind Turbines. CAA. CAA. (2014 (a)). CAP 393 Air Navigation: The Order and the Regulations. CAA. CAA. (2014 (b)). Visual Flight Rules Chart Scotland Edition 27. CAA. DECC. (2011). Overarching National Policy Statement for Energy. DECC. MOD. (2014 (a)). Military Aeronatical Information Publication. MOD. MOD. (2014 (b)). Defence Infrastructure Organisation (DIO) consultation response (Ref: 19966). MOD. NATS. (2013). NATS Technical and al Assessment (TOPA) W(F) NATS. NATS. (2014). UK Integrated Aeronautical Information Package. NATS. Osprey. (2014) BRUK Knockskae Aviation Impact Assessment.. Prestwick Airport. (2014 (a), July 17). Consultation Response. Prestwick Airport. (2014 (b)). Scoping Consultation Response. RenewableUK. (2012). Guidance on Low Flying Aircraft and Onshore Tall Structures Including Anemometer Masts and Wind Turbines. RenewableUK.