Linfairn Wind Farm Addendum Appendix A12: Aviation Report. APPENDIX A12: Aviation Report

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1 SgurrEnergy Ltd Linfairn Wind Farm Addendum Appendix A12: Aviation Report APPENDIX A12: Aviation Report

2 SgurrEnergy Ltd Linfairn Wind Farm Addendum Appendix A12: Aviation Report

3 Aviation Impact Assessment for the proposed Linfairn Wind Farm Prepared for SgurrEnergy Ltd by Charles Morelli BEng 5 December 2014 AARDVaRC Ltd, PO Box 10785, Sudbury, Suffolk, CO10 3AY T: +44 (0) E: charles@aardvarc.ltd.uk W: Copyright 2014 AARDVaRC Ltd. All rights reserved.

4 1 Executive Summary 1.1 Background SgurrEnergy Ltd is developing a proposal for a wind farm at Linfairn, south of Straiton in South Ayrshire. AARDVaRC Ltd has been retained to assess the impacts on aviation of the development. As currently planned, the proposal is for 17 wind turbines of up to 126.5m maximum blade tip height, each with up to 3.2 megawatt generating capacity. All analyses were conducted in accordance with normal UK practice. 1.2 Aviation Receptors The aviation receptors considered in detail in this assessment are listed below, with a brief description of the possible impacts that were investigated Aerodromes The obstacle environment at Prestwick Airport 25km north of the site was considered, and possible electromagnetic interference with it radio communications, navigation and surveillance (CNS) systems other than its primary surveillance radar (PSR), considered separately investigated. The obstacle environment at the unlicenced Kilkerran Airstrip 5km west-northwest of the site was also assessed Radar Systems Effects on the PSRs at Prestwick Airport, the NATS (formerly National Air Traffic Services) En-Route plc (NERL) Lowther Hill 50km east of the site and Ministry of Defence (MoD) West Freugh 52km south-southwest of the site were assessed. PSRs at Glasgow Airport, Edinburgh Airport and Great Dun Fell are outside the scope of this study. However, given their significance to wind farm development in the wider region, sufficient high level analyses were conducted to confirm that these will not be affected by the proposal En-Route CNS Systems The NERL radio navigation beacon at Turnberry 12km west-northwest of the site and radio communications site at Brown Carrick Hill 15km north-northwest of the site were assessed for electromagnetic interference Airspace, Air Traffic and Military Low Flying An assessment was made of the surrounding airspace, and likely air traffic, including effects on military low flying training in the Low Flying Area 20 Tactical Training Area (LFA20(T)) within which the proposed wind farm is situated. 1.3 Conclusions Prestwick Airport Radar Impact The magnitude of impact from the proposed Linfairn wind farm on the Prestwick Airport primary surveillance radar (PSR) is assessed as small. Linfairn Wind Farm 2 Aviation Impact Assessment

5 The magnitude of cumulative impact in conjunction with neighbouring wind farms is assessed as medium Mitigation Radar mitigation is likely to be necessary to avoid an objection from Prestwick Airport. Mitigation technologies expected to be available within the lifetime of a planning consent and acceptable to Prestwick Airport include (but are not necessarily limited to): Aveillant s Holographic Radar, and C-Speed s Lightwave Radar. It is understood that effective radar mitigation for the recently consented Dersalloch wind farm will be needed and that this will lead to common mitigation solutions for many wind farms, including that proposed at Linfairn Residual Impact Following mitigation, the residual magnitude of impact on the Prestwick Airport PSR is assessed as negligible; the residual magnitude of cumulative impact on the Prestwick Airport PSR is assessed as beneficial and medium Low Flying Impact The magnitude of impact from the proposed Linfairn wind farm on the military low flying activities in Low Flying Area 20 Tactical Training Area (LFA20(T)) is assessed as negligible. The magnitude of cumulative impact in conjunction with neighbouring wind farms is assessed as small Mitigation It is envisaged that infra-red lighting will be required on a number of turbines to mitigate any potential impacts Residual Impact Following the above mitigation, the residual magnitude of impact is assessed as negligible, and the residual magnitude of cumulative impact is assessed as negligible Airspace and Air Traffic The magnitude of impact on airspace and air traffic is assessed as negligible. There will be no cumulative impact. No mitigation is required Other Receptors There will be no impact on other aviation receptors from the proposed Linfairn wind farm and hence no cumulative impact. Linfairn Wind Farm 3 Aviation Impact Assessment

6 2 Contents 1 Executive Summary Background Aviation Receptors Conclusions Contents Introduction Linfairn Wind Farm Units and Datums AARDVaRC Ltd The Author Proposed Linfairn Wind Farm Overview Layout Layout Chart Baseline Aviation Environment Introduction Identification of Aviation Receptors Receptor Data Impact Assessment Outline Prestwick Airport Prestwick Airport PSR Lowther Hill PSR (NERL) West Freugh PSR (MoD) Kilkerran Airstrip Low Flying and LFA20(T) Turnberry Navigation Aid and Brown Carrick Hill Site Airspace and Air Traffic Summary of Proposed Mitigation Overall Impact Summary Effects of Wind Turbines on Radar Background Air Traffic Control Radar Services Deconfliction Service Traffic Service Radar Services in Areas of Radar Clutter Flight Safety and Expediency Conclusions Prestwick Airport Radar Low Flying Airspace and Air Traffic Other Receptors Appendix 1 Line-of-Sight Assessment Method... A1-1 Background... A1-1 Standard Refraction Model... A1-1 Line-of-Sight Profile Chart... A1-1 Area Coverage Chart... A1-1 Appendix 2 Radar Line-of-Sight Terrain Profiles... A2-1 Prestwick Airport PSR Terrain Profile Charts... A2-1 Lowther Hill PSR Terrain Profile Charts... A2-2 West Freugh PSR Terrain Profile Chart... A2-2 Linfairn Wind Farm 4 Aviation Impact Assessment

7 3 Introduction 3.1 Linfairn Wind Farm SgurrEnergy is developing a wind farm proposal near Linfairn, south of Straiton in South Ayrshire. There are 17 wind turbines proposed of up to 126.5m maximum blade tip height and each with up to 3.2 megawatt generating capacity. There are concerns regarding its impact on aviation interests in the regions, especially but not exclusively on radar and military low flying operations. AARDVaRC Ltd has been retained to conduct this aviation impact assessment. It has conducted radar line-of-sight assessments to radar systems that may be affected, and considered the wind farm as a potential obstruction to aerial navigation given the airspace it would occupy and nearby aerodromes. Possible electromagnetic interference on communications, navigation and surveillance systems other than radar was also investigated. Standard UK guidance was applied in this assessment. It was established that neither Met Office rainfall radars, RAF Spadeadam threat radar sites, nor the Eskdalemuir seismic array are close enough to be affected by the site and hence are outside the scope of this study. Similarly, the radars at Glasgow and Edinburgh Airports, and at Great Dun Fell, were outside the geographical study area (although high level analyses were conducted to confirm these systems would not be affected by the proposed wind farm since they are commonly affected by wind farm development in the wider region). It is noted that neither the Civil Aviation Authority (CAA) nor the Ministry of Defence (MoD) normally respond to pre-planning wind farm enquiries from developers at present. However, this assessment has considered all issues that affect these stakeholders, in addition to those affecting NATS (formerly National Air Traffic Services) En-Route plc (NERL) and aerodrome operators. Where possible, aviation stakeholder s online self-assessment tools have been used to verify the findings of this analysis. 3.2 Units and Datums Unless otherwise stated, locations are given in British National Grid OSGB36 Eastings/ Northings formats, with WGS 84 longitude and latitude coordinates also stated where appropriate. Azimuths/ bearings are given as British National Grid bearings. Heights, elevations and flight altitudes are given in metres and feet above the appropriate datum (i.e., above mean sea level (amsl) equivalent to above OS datum (AOD) for elevations and flight altitudes, above either ground level or touchdown for heights); note that the units used in source data are generally given first, with the alternative unit shown in parenthesis. 3.3 AARDVaRC Ltd AARDVaRC Ltd was founded in April 2010 to provide expert aviation, defence and other technical consultancy services to the renewable energy and other industries. These services are particularly focussed on renewable technologies, however, this expertise is equally applied to other industries, e.g., AARDVaRC provided its expert aviation and defence services for the recently consented Cherry Orchard tower development in south London. AARDVaRC s expertise lends itself to a wide range of technical issues relating to renewable energy development. For example, the company has developed an Linfairn Wind Farm 5 Aviation Impact Assessment

8 analytical model to assess sun glint (reflections) from large-scale solar farm developments, particularly for aviation impact assessment. 3.4 The Author Charles Morelli holds a BEng degree in Aeronautical Engineering from Bath University. He was commissioned into the Royal Regiment of Artillery, serving as a Forward Observation Officer managing battlefield indirect fire and electronic warfare assets for the local commander before taking helicopter flying duties in the Army Air Corps. Here he served as second-in-command of an anti-tank helicopter squadron, and was the Army Aviation subject matter expert and project manager compiling flying regulations for the newly formed Joint Helicopter Command (JHC). Since leaving the Army in 2004, he has focussed on technical and specialist aviation analysis for renewable energy developments working in 2 consultancy companies until founding AARDVaRC in The author has an in-depth knowledge of the aviation industry, electromagnetic propagation including reflections of light (i.e., glint and glare), wave theory, and of communications, navigation and surveillance (CNS) equipment. He has conducted detailed assessments of aviation and electromagnetic issues, and mitigation studies for many renewable energy and other developments including for Clyde, Fallago Rigg, Middlemoor, Stoke Heights and many other wind farms. Charles is also a glider pilot and holds a Private Pilot s Licence (PPL) for light singleengined aeroplanes. Other interests and hobbies include amateur astronomy, renewable energy technologies and cycling. Linfairn Wind Farm 6 Aviation Impact Assessment

9 4 Proposed Linfairn Wind Farm 4.1 Overview The proposed Linfairn wind farm site is located to the south of Straiton, Dumfries and Galloway. There are 17 proposed wind turbines of up to 126.5m maximum blade tip height (based on 101m rotor diameter and 76m hub height) each with a generating capacity of up to 3.2 megawatts (MW), giving an overall capacity of up to 54.4MW. As shown in the next section, the base of the highest turbine is 306m above OS datum (AOD), giving a maximum blade tip elevation of 432.5m AOD/ 1,419ft above mean sea level (amsl). 4.2 Layout Turbine locations are given below (note that turbine numbering does not start at 1 and is not always consecutive). Turbine Easting Northing Site Elevation /m Table Wind Turbine Schedule Site elevations above are interpolated from OS Digital Terrain Model (DTM) data at the base of each turbine location, and are measured AOD. These turbine locations are shown on the chart below. Linfairn Wind Farm 7 Aviation Impact Assessment

10 4.3 Layout Chart The following chart shows the turbine positions overlaid as numbered, red crossed circles on a 1:50,000 scale OS Landranger map, orientated with British National Grid North at the top. Note the Kilkerran landing strip in the northwest corner, and the nearest turbines of the Hadyard Hill wind farm in the southwest corner, both discussed later. Ordnance Survey Crown Copyright All rights reserved. Licence number Linfairn Wind Farm 8 Aviation Impact Assessment

11 5 Baseline Aviation Environment 5.1 Introduction Various aviation infrastructure and airspace users may be susceptible to some form of beneficial or detrimental impact from wind turbine developments in their vicinity so the local airspace and airspace users are considered. Communications, navigation and surveillance (CNS) equipment may be subject to interference to their radio frequency (rf) transmissions from wind turbines, mainly through reflections, but to a much lesser (and arguably, insignificant) extent from the blocking of radio signals. Of these, primary surveillance radar (PSR) systems are generally most affected as wind turbines within line-of-sight (LoS) of Doppler PSRs can degrade their performance at considerable range from the radar antenna (whereas effects on other CNS tends to reduce significantly with range). It should be noted that secondary surveillance radar (SSR) systems, whilst in theory susceptible to impacts at greater distances, are not normally a concern unless within 10km of a wind farm. In addition, in the vicinity of aerodromes, aircraft necessarily fly low so the obstacle environment around such sites must be considered. Airspace, airspace users and potential en-route navigation issues away from aerodromes are also considered. Finally, although not specifically aviation assets, Met Office rainfall radar systems, and the seismic array at Eskdalemuir are also generally considered alongside other aviation infrastructure for convenience as they are safeguarded by the MoD, one of the main aviation stakeholders in wind energy development. 5.2 Identification of Aviation Receptors The following table shows the radii from the proposed wind farm within which the various receptor groups were considered in detail in this assessment. Note that some radii given below are greater than the official safeguarding radii applied by stakeholders in order to ensure they are not missed; others, specifically those for PSR systems are based on AARDVaRC s knowledge of these systems: it is rare for issues to occur beyond the distances given: nevertheless, the possibility of effects on systems beyond these radii are considered, and where there is a potential impact such receptors are included in the detailed assessment. Receptor Group Air Defence and En-Route PSR Airfield and Range Control PSR, PAR, and RAF Spadeadam Threat Radars All SSR Systems Other CNS Licenced Aerodromes (with one or more runways longer than 1km) Other Licenced Aerodromes and all Unlicenced Aerodromes Met Office Rainfall Radar Eskdalemuir Seismic Array Radius 100km 60km 30km 15km 30km 15km 30km 60km Although the PSR systems can theoretically be affected by wind turbines beyond the specified distances, in practice, this seldom occurs due to terrain masking effects magnified by the Earth s curvature. Nevertheless, all PSR systems have been considered, and systems that may be affected beyond these distances included in the detailed analysis: in this instance none were. Linfairn Wind Farm 9 Aviation Impact Assessment

12 5.3 Receptor Data Outline Receptors described here are within the distances stated above for consideration in this assessment. There are no air defence radars, SSR, PAR or threat radar systems within the specified radius. The following receptors were included in the detailed assessment: Prestwick Airport (all issues less for PSR) and Kilkerran Airstrip; Prestwick Airport, Lowther Hill, and West Freugh PSRs; Turnberry radio navigation aid and Brown Carrick Hill radio communications site; Airspace and air traffic (including military low flying) Prestwick Airport Prestwick Airport is located approximately 25km north of the Linfairn site. It is an international airport with a main runway just under 3km long orientated northwest to southeast, and a second runway just over 1.8km long orientated northeast to southwest. The airport is equipped with radar (discussed next) and various radio navigation aids; it also has a number of established instrument flight procedures enabling operation in adverse weather conditions. The aerodrome reference point is at approximately NGR: NS Prestwick Airport PSR Prestwick Airport operates an S-Band EN4000 PSR approximately 25km north of the Linfairn site. This is used for air traffic control purposes, providing radar services for inbound and outbound, as well as transiting, air traffic. The radar antenna location used was NGR: NS , 35.25m AOD Lowther Hill PSR (NERL) Lowther Hill, approximately 50km east of the Linfairn site, is one of a number of remote radar sites operated by NERL. The PSR equipment is a long range Raytheon ASR23 and is used principally to provide air traffic services to en-route air traffic, although the radar data also serves other purposes. The radar antenna location used was NGR: NS , m AOD West Freugh PSR (MoD) West Freugh operates an S-Band Watchman PSR, approximately 52km southsouthwest of the Linfairn site, for range control functions, covering the live firing and bombing ranges at Luce Bay. The radar antenna location used was NGR: NX , 29.3m AOD Kilkerran Private Airstrip There is an unlicenced private airstrip on the Kilkerran estate, 5km west-northwest of the Linfairn wind farm site. The runway is approximately 800m long and orientated northeast to southwest. The location of the runway mid-point is approximately NGR: NS Linfairn Wind Farm 10 Aviation Impact Assessment

13 5.3.7 Turnberry VOR/ DME Radio Navigation Aid There is an en-route navigation site at Turnberry operated by NERL, approximately 12km west-northwest of the Linfairn site. This has combined very high frequency (VHF) omni-directional ranging (VOR) and distance measuring equipment (DME) radio navigation beacons. These allow navigational fixes for suitably equipped aircraft by giving bearing and distance information from the beacon. The location of the Turnberry beacon is approximately NGR: NS Brown Carrick Hill Radio Site There is a remote air-to-ground and ground-to-air radio communications site at Brown Carrick Hill operated by NERL, approximately 15km north-northwest of the Linfairn site, providing voice communications with en-route air traffic in the region. The location of the Brown Carrick Hill site is approximately NGR: NS Low Flying and LFA20(T) The UK Low Flying System extends up to a height of 2,000ft above the surface across most of the UK with fast jet low flying permitted to a minimum separation distance from the ground and other obstructions of 250ft, and helicopter low flying down to ground level. However, the Linfairn site also lies in Low Flying Area 20 Tactical Training Area (TTA), known as LFA20(T) in which specially authorised fast jet training may take place down to a minimum separation distance of 100ft Airspace The Linfairn site lies within the Scottish Flight Information Region (FIR), extending from the surface to Flight Level (FL) 245 approximately 24,500ft amsl; above this level the Scottish Upper Information Region (UIR) is established. The airspace structure surrounding the Linfairn site is shown in the following table. Lower Limit Upper Limit Classification Notes FL660 (c. 66,000ft) N/A G (uncontrolled) 'Open UIR' FL245 (c. 24,500ft) FL660 (c. 66,000ft) C (controlled) Upper Airspace. Upper air route UM87. FL195 (c. 19,500ft) FL245 (c. 24,500ft) C (controlled) Scottish Terminal Manoeuvring Area (TMA) 5,500ft FL195 (c. 19,500ft) D (controlled) Scottish TMA Surface 5,500ft G (uncontrolled) 'Open FIR' There are no danger areas or other airspace restriction in the vicinity of the Linfairn site. Linfairn Wind Farm 11 Aviation Impact Assessment

14 Air Traffic The various types of air traffic that may operate in the vicinity of Linfairn are described in the following table. Air Traffic Prestwick Airport traffic Kilkerran Airstrip traffic En-route traffic (in controlled airspace) En-route traffic (outside controlled airspace) Notes Within controlled airspace in the vicinity of the proposed wind farm, most Prestwick Airport arrivals and some departures are expected to be in receipt of a radar service using the Prestwick Airport PSR, the remainder using enroute radars including Lowther Hill. Some Prestwick Airport traffic outside controlled airspace may be in receipt of a radar service using the Prestwick Airport PSR. Prestwick Airport has instrument flight procedures (either arrivals or departures) established in the vicinity of the Linfairn Site all within controlled airspace, i.e., above 5,500ft amsl. Some Prestwick Airport traffic (either arrivals or departures) passing the Linfairn site will effectively be in the en-route phase of flight, either inside or outside controlled airspace. Any air traffic flying to or from Kilkerran will effectively be in the en-route phase of flight in the vicinity of the Linfairn site. Traffic will be mainly commercial, but some military, helicopter and general aviation traffic may be expected. There are no airways below FL245 in the vicinity of the Linfairn site; above FL245, some traffic will operate along route UM87. Such traffic is expected to receive a radar service using enroute radars, including Lowther Hill, but not Prestwick Airport s radar. Above FL100 all aircraft are required to carry a transponder, so SSR-only coverage may be sufficient. There is no reason to expect high volumes of en-route traffic outside controlled airspace near the Linfairn site. Such traffic includes the following. Military low flying traffic: Fast jet traffic may routinely operate down to height of 250ft, and some specifically authorised flights will take place down to a height of 100ft within LFA20(T). Helicopters may operate down to ground level. Since tactical flying favours low ground and valleys, it is considered unlikely that significant volumes of low flying traffic would operate very close to the proposed wind farm which is on elevated terrain. Helicopter traffic: Civilian helicopters routinely operate down to a minimum separation of 500ft from vehicles, structures and people, and for survey work may operate at lower levels. General Aviation (GA) traffic: GA traffic may operate down to a minimum separation of 500ft from vehicles, structures and people, and may receive a radar service using the Prestwick Airport PSR Other Receptors The following radars in the wider region are outside the zones considered specifically for this report: Glasgow Airport PSR; Edinburgh Airport PSR; Great Dun Fell en-route PSR. Nevertheless, for completeness these were considered briefly as many wind farms in the wider region affect them. Although not detailed in this report, sufficient high-level assessments were conducted to confirm that they will not be affected. Linfairn Wind Farm 12 Aviation Impact Assessment

15 Locations Chart The following chart shows the locations of the various receptors. Proposed Linfairn wind turbines are marked as red dots inside the green shaded box; the LFA20(T) boundary is marked with the green line; radars are marked with orange dots, and other CNS by yellow dots; the runway at Kilkerran Airstrip is marked by an exaggerated green line. Prestwick Airport PSR Brown Carrick Hill Radio Communications Site Turnberry VOR/ DME Beacon Kilkerran Airstrip Lowther Hill PSR Linfairn Wind Farm Site LFA20(T) Boundary West Freugh PSR Contains Ordnance Survey data Crown copyright and database right Linfairn Wind Farm 13 Aviation Impact Assessment

16 6 Impact Assessment 6.1 Outline Overview The levels of impact used in this assessment are defined in the following table. Level of Impact Nil/ no impact Negligible Small Medium Large Description of Impact No impact that can be routinely measured. A level of impact that may be measurable, but would not normally be noticeable in day-to-day operations. A measurable impact on the receptor that is noticeable in day-to-day operations, but requires little or no management or change to procedures. An impact that necessitates noticeable, but not excessive, changes to procedures or requires deliberate effort to manage. An impact that necessitates major changes to procedures or requires an excessive effort to manage. Impacts may be either beneficial or adverse. Unless otherwise stated, impacts identified are assumed to be adverse and will increase during commissioning to a maximum during the operation phase of the project, and decrease during decommissioning to nil when fully decommissioned. Guidance from CAA document Civil Aviation Publication (CAP) 764 CAA Policy and Guidelines on Wind Turbines was used throughout this assessment Assessment of Radar Line-of-Sight Radar line-of-sight assessment is commonly used for impact assessment and is recommended by CAP 764 and EUROCONTROL-GUID-0130 EUROCONTROL Guidelines on How to Assess the Potential Impact of Wind Turbines on Surveillance Sensors. The method used for this assessment is described in Appendix 1. Radar line-of-sight (LoS) analysis was conducted for the respective radar systems in accordance with the method described in Appendix 1 in order to estimate radar impact. The wind turbine ceiling height (i.e., the wind turbine maximum blade tip height at each location that just reaches the base of radar coverage as predicted through LoS analysis) for each wind turbine/ radar combination was calculated. This enabled the visible turbine height (the difference between the turbine height and the turbine ceiling height negative if the turbine is not visible) of the proposed wind turbines to be calculated as an indication of radar visibility. Calculated ceiling and visible turbine heights are given to the nearest whole metre. A wind turbine taller than the ceiling height at a particular location will usually affect the radar in a manner typical of wind turbines. Typical wind turbine radar impacts are well documented and are summarised later in Section 7. Linfairn Wind Farm 14 Aviation Impact Assessment

17 Terrain profiles between radars and selected wind turbines are shown at Appendix 2 to illustrate the findings Assessment of Obstruction to Aerial Navigation In addition to CAP 764, guidance on the assessment of obstruction to aerial navigation was taken from various sources, depending on the nature of the receptor, as follows. CAP 168 Licensing of Aerodromes, and CAP Safe Operating Practices at Unlicensed Aerodromes provide guidance for obstacles near licenced and unlicenced aerodromes. ICAO Document 8168 PANS-OPS (Procedures for Aerial Navigation Services Operations), and CAP 785 Approval Requirements for Instrument Flight Procedures for Use in UK Airspace provide guidance for obstacles that may affect instrument flight procedures at airports and in the en-route environment. CAP 393 Air Navigation: The Order and the Regulations provides guidance on en-route aviation obstacles Assessment of Radio Interference Guidance on siting of buildings and structures to avoid radio interference to equipment other than PSR is taken from CAP 670 Air Traffic Services Safety Requirements Cumulative Impacts Overview Wind farms in the surrounding area can have a significant cumulative impact, principally on radar, but also on low flying training. Cumulative Radar Impact For radar issues, discussed later, the worst case impact is that a controller may decide to keep controlled aircraft at least 5nm (9.3km) from unknown radar returns. If clutter from other wind farms is between, say, 5nm and 10nm ( km), the sterilised zones cover a large area with no gaps through which to vector traffic. As the separation increase above 10nm (18.5km), gaps become wider, and as separation increase beyond 30km, cumulative radar issues should diminish rapidly. Therefore, AARDVaRC generally considers cumulative radar impact to a 30km radius from the proposed wind farm. Cumulative Low Flying Impact RAF policy for operational low flying training (within TTAs) at 100ft height is that 20 minutes of continuous flight at that height is necessary for useful training. A proliferation of wind farms in a TTA may cause an interruption to the training, negating any benefit. However, pilots have the option to fly around wind farms instead of climbing over them, providing that such avoidance doesn t bring them too close to another wind farm. AARDVaRC considers that 30 seconds high speed flight time between wind farms should be sufficient to ensure this. To that end, AARDVaRC considers cumulative low flying impact to a radius of 10km from the proposed wind farm (39 seconds flight time at 500kts), noting that when flying tactically, aircraft do not fly straight for more than a few seconds; the maximum speed in the low flying system is normally 450kts, with 500kts permitted below 150ft only for short term tactical activity. Linfairn Wind Farm 15 Aviation Impact Assessment

18 Other Wind Farms The following table lists wind farms in various stages of development known to be within 30km of the Linfairn site. It is taken from data provided by SgurrEnergy Ltd. Status Wind Farm Name Size and Relative Location Operational Consented (including under construction) In the Planning System Hadyard Hill Mark Hill Windy Standard Arecleoch Hare Hill Dersalloch Neilstonside Ailsa Hospital Torrs Hill Windy Standard Ext Kilgallioch Glenchamber Dalmorton / Knockskae Grangestone Industrial Estate Ashmark Hill Straid Farm Afton High Cumnock A 53-turbine wind farm, 6.6km southwest of the Linfairn site. A 28-turbine wind farm, 16.8km southwest of the Linfairn site. A 36-turbine wind farm, 23.0km east of the Linfairn site. A 60-turbine wind farm, 25.1km southwest of the Linfairn site. A 20-turbine wind farm, 28.0km east of the Linfairn site. A 22-turbine wind farm, 3.4km east of the Linfairn site. A single-turbine development, 11.8km north of the Linfairn site. A single-turbine development, 15.2km north of the Linfairn site. A 2-turbine development, 17.8km southeast of the Linfairn site. A 30-turbine wind farm, 21.1km east of the Linfairn site. A 96-turbine wind farm, 26.3km southwest of the Linfairn site. An 11-turbine wind farm, 26.9km southwest of the Linfairn site. A 19-turbine wind farm, adjacent on the north side of the Linfairn site. A single-turbine development, 15.5km west of the Linfairn site. A 7-turbine wind farm, 21.2km east of the Linfairn site. A 14-turbine wind farm, 22.9km southwest of the Linfairn site. A 27-turbine wind farm, 25.1km east of the Linfairn site. An 8-turbine wind farm, 27.1km northeast of the Linfairn site. Within 10km of the proposed development, there are currently: one operational wind farm; one consented/ under construction; and a planning application for a wind farm adjacent to it. Within 15km of the proposed development, there are currently: one operational wind farms; two consented/ under construction; and a planning application for a wind farm adjacent to it. Linfairn Wind Farm 16 Aviation Impact Assessment

19 Within 30km of the proposed development, there are currently: 5 operational wind farms 7 consented/ under construction; and 6 in the planning system. Detailed analysis of each of these sites for radar, low flying, or other issues is beyond the scope of this report. However, it is known that some of the operational wind farms listed do affect Prestwick Airport s PSR: this is discussed later. 6.2 Prestwick Airport Analysis and Discussion The possible impacts on Prestwick Airport from the proposed wind farm (other than on its radar, discussed later) are obstruction to aerial navigation and on radio communications, navigation, or surveillance (CNS) systems excepting the PSR, discussed separately. It is noted that the CAA would normally recommend consulting airports on such issues (i.e., airports without radar equipment) within 17km of a proposed wind farm. Prestwick Airport is outside this radius so issues are not expected (although the analysis was conducted rigorously nevertheless) Obstruction to Aerial Navigation Prestwick Airport has various obstacle limitation surfaces established, and instrument flight procedures with their own obstacle protection areas, safety altitudes and ATC surveillance minimum altitudes for aircraft flying out of sight of the surface. None of these will be affected by the proposed wind farm. There will be no impact on operations at Prestwick Airport due to the proposed wind farm as an obstruction to aerial navigation CNS Systems Prestwick Airport operates a number of CNS systems (other than its PSR). The proposed wind farm is outside all safeguarding distances for such systems. There will be no impact on CNS systems other than radar at Prestwick Airport due to the proposed wind farm Summary of Impact There will be no impact on Prestwick Airport from the proposed wind farm from obstruction to aerial navigation or interference with CNS systems other than radar. As there will be no impact from this wind farm, there will be no cumulative impact when considered with other nearby wind farms. Linfairn Wind Farm 17 Aviation Impact Assessment

20 6.3 Prestwick Airport PSR Analysis Results Line-of-sight analysis for all wind turbines was conducted with respect to the Prestwick Airport PSR. The wind turbine ceiling heights and visible turbine heights for each wind turbine with respect to the Prestwick Airport PSR are shown in the following table, with predicted turbine visibility. Turbine Turbine Ceiling Height /m Visible Turbine Height /m Notes Rotor partially visible, tower is not visible Rotor mostly visible, tower partially visible Rotor entirely visible, tower mostly visible Rotor entirely visible, tower mostly visible Rotor partially visible, tower is not visible Rotor mostly visible, tower partially visible Rotor mostly visible, tower partially visible Rotor entirely visible, tower mostly visible Rotor entirely visible, tower mostly visible Rotor entirely visible, tower mostly visible Rotor half visible, tower barely visible Rotor mostly visible, tower half visible Rotor mostly visible, tower half visible Rotor almost entirely visible, tower mostly visible Rotor almost entirely visible, tower half visible Rotor mostly visible, tower partially visible Rotor entirely visible, tower mostly visible. Radar line-of-sight terrain profile charts for selected turbines (marked in bold on the table above) are shown at Appendix 2. At 25km from Prestwick Airport, and away from the approach paths to any instrument runway, the magnitude of impact from the proposed wind farm on Prestwick Airport s PSR is assessed as small Cumulative Impact There are 5 operational wind farms within 30km of the proposed development. Some of these are known to affect Prestwick Airport s PSR (with others beyond 30km). Given the number of other wind farms that affect Prestwick s radar, controller workload to manage these sites is likely to be great enough to reduce the capacity of the airport. The magnitude of cumulative impact is therefore assessed as medium Discussion The line-of-sight exposure of all proposed turbines to the Prestwick Airport combined with the radar/ wind farm geometry, likely radar system parameters and consideration of the terrain profiles, strongly suggests that the radar will be affected by the wind farm. Further analysis (i.e., a radar detectability study) is beyond the scope of this assessment, but is unlikely to alter its overall conclusions for the wind. Linfairn Wind Farm 18 Aviation Impact Assessment

21 Combined with the cumulative impact, Prestwick Airport is expected to object to this proposal unless robust mitigation is put in place Mitigation There are a number of radar mitigation technologies that may be applied, and at least 2 are mature enough to be seriously considered. Notably, the recently consented Dersalloch wind farm is understood to require effective mitigation for the Prestwick Airport PSR, almost certainly from one of the 2 following, relatively mature, mitigation technologies. Aveillant s Holographic Radar. C-Speed s Lightwave Radar. It is anticipated that Prestwick Airport will be in a position to agree a standard PSR mitigation plan with developers shortly, based on the mitigation applied for Dersalloch. Other technologies include: use of additional radar sensors, as used (or shortly to be used) in at least 3 locations in the UK; low radar cross section wind turbine technology, which was used at a site in view of Glasgow Airport s radar; as well as other competing technologies under development. Detailed description of these (or other) technologies is beyond the scope of this report, but there is plenty of supporting evidence that effective mitigation, acceptable to Prestwick Airport, will almost certainly be available within the lifetime of a planning consent, and is expected to reduce the magnitude of residual impact to negligible. It should be noted that if one of the two radar systems listed above (i.e., the Aveillant or C-Speed product or similar system) is used as mitigation, this should have further benefits, not only in allowing additional wind farm development, but also in reducing the impact from existing wind farms, greatly improving the overall radar environment for Prestwick Airport. This beneficial residual impact is assessed to be medium Summary of Impact The magnitude of impact of the proposed wind farm on its own on the Prestwick Airport PSR (and operations that depend on the PSR) is assessed to be small. The magnitude of cumulative impact of the proposed wind farm in conjunction with other wind farms in the vicinity on the Prestwick Airport PSR (and operations that depend on the PSR) is assessed to be medium. Following effective mitigation, the magnitude of residual impact of the proposed wind farm on the Prestwick Airport PSR is assessed to be negligible. Following effective mitigation, the magnitude of residual cumulative impact of the proposed wind farm in conjunction with other wind farms in the vicinity on the Prestwick Airport PSR is assessed to be beneficial and medium. Linfairn Wind Farm 19 Aviation Impact Assessment

22 6.4 Lowther Hill PSR (NERL) Analysis Results Line-of-sight analysis for all wind turbines was conducted with respect to the Lowther Hill PSR. The wind turbine ceiling heights for each wind turbine with respect to the Prestwick Airport PSR are shown in the following table, with predicted turbine visibility. Turbine Turbine Ceiling Height /m Visible Turbine Height /m Notes Turbine is not visible Turbine is not visible Turbine is not visible Turbine is not visible Turbine is not visible Turbine is not visible Turbine is not visible Turbine is not visible Turbine is not visible Turbine is not visible Turbine is not visible Turbine is not visible Turbine is not visible Turbine is not visible Turbine is not visible Turbine is not visible Turbine is not visible. All proposed wind turbines are below the line-of-sight of the Lowther Hill PSR so there is assessed to be no impact on this radar. This is verified by NERL s online selfassessment tool which shows that the wind farm site is in an area in which 140m-tall turbines are expected to have no impact. Radar line-of-sight terrain profile charts for Turbine 25 (marked in bold on the table above) is shown at Appendix Cumulative Impact As there will be no impact on the Lowther Hill PSR, there will be no cumulative impact Discussion There are no concerns to be addressed with respect to the Lowther Hill PSR Mitigation No mitigation will be required for the Lowther Hill PSR Summary of Impact There will be no impact from the proposed development on the Lowther Hill PSR and hence no cumulative impact. Linfairn Wind Farm 20 Aviation Impact Assessment

23 6.5 West Freugh PSR (MoD) Analysis Results Line-of-sight analysis for all wind turbines was conducted with respect to the West Freugh PSR. The wind turbine ceiling heights for each wind turbine with respect to the West Freugh PSR are shown in the following table, with predicted turbine visibility. Turbine Turbine Ceiling Height /m Visible Turbine Height /m Notes Turbine is not visible Turbine is not visible Turbine is not visible Turbine is not visible Turbine is not visible Turbine is not visible Turbine is not visible Turbine is not visible Turbine is not visible Turbine is not visible Turbine is not visible Turbine is not visible Turbine is not visible Turbine is not visible Turbine is not visible Turbine is not visible Turbine is not visible. Radar line-of-sight terrain profile charts for Turbine 25, the least well hidden turbine (marked in bold on the table above) is shown at Appendix 2. All proposed wind turbines are below the line-of-sight of the West Freugh PSR. Therefore, there is assessed to be no impact on this radar. This is verified by the MoD s online self-assessment tool which shows that the wind farm site is in an area in which 140m-tall turbines are expected to have no impact Cumulative Impact As there will be no impact on the West Freugh PSR, there will be no cumulative impact Discussion There are no concerns to be addressed with respect to the West Freugh PSR Summary of Impact There will be no impact from the proposed development on the West Freugh PSR and hence no cumulative impact. 6.6 Kilkerran Airstrip Analysis CAA guidance in CAP 764 is that aerodromes of this nature do not normally need to be consulted when more than 4km from a proposed wind farm. Linfairn Wind Farm 21 Aviation Impact Assessment

24 Furthermore, the runway is orientated approximately north-northwest to southsoutheast, nearly perpendicular to the direction of the proposed wind farm (eatssoutheast of the airstrip), so the wind farm is in almost the least sensitive direction. There will be no impact from the proposed wind farm on operations at Kilkerran Airstrip Discussion There are no concerns to be addressed with respect to the Kilkerran Airstrip Summary of Impact There will be no impact from the proposed development on the Kilkerran Airstrip and hence no cumulative impact. 6.7 Low Flying and LFA20(T) Analysis Results Normally, low flying military aircraft use the principle of see and avoid for obstacle avoidance (including at night when night vision goggles are used), so there will be no impact on safety. Problems can arise where low flying aircraft are using a choke point in the low flying system (e.g., flying between low flying avoidance areas) and there is relatively low controlled airspace or other vertical constraint above the wind turbines; these restrict the freedom of aircraft to fly around or over the wind farm. Neither condition applies at the proposed wind farm. In addition, for TTAs such as LFA20(T), due to the nature of operational low flying it is undesirable to force an aircraft to climb over a wind farm, so the main concern is whether the wind farm is located on a preferred tactical route, and whether cumulative issues would prevent flying around the proposed development. The proposed wind farm does not appear to lie on a route that would normally be chosen for tactical flying, as it is on high ground and there is a valley to the east of the site which would be preferable for such flight. Part of the Hadyard Hill wind farm lies within 10km of some proposed Linfairn wind turbines, although most of its turbines are outside this distance. The consented Dersalloch wind farm, and the proposed Dalmorton / Knockskae (in the planning system) are both within 10km of the Linfairn site (the latter being adjacent on the north side of the site) Discussion As the site is located on high ground, it is assessed that its impact on low flying and on LFA20(T) will be negligible. As there is just one operational wind farm within 10km (based on the above analysis of site centres), and one consented and another in the planning within 10km, the cumulative impact from the Linfairn proposal is assessed to be small. The MoD objected to the Section 36 application for the wind farm. This objection was based on a previous 25 turbine layout and since then the Project has been reduced to 17 turbines and limited to a single hill. The revised layout coordinates were submitted to the MoD and a response was received with the objection upheld. Based on further analysis undertaken for the addendum, it is not expected that this objection cannot be Linfairn Wind Farm 22 Aviation Impact Assessment

25 overcome and consultation is on-going with the MoD to agree a solution and remove the objection Mitigation In recent years, the MoD has often requested low intensity red, or infrared (to minimise visual impact) lights to be fitted on the nacelles of prominent wind turbines in wind farms to assist pilots flying at night using night vision goggles. When consulted, it is considered likely that this request will be made for the proposed wind farm. It is proposed that infra-red lighting will be required on a number of turbines. Consultation is on-going with the MoD in this respect to confirm and agree requirements. The residual impact, following such mitigation, will remain negligible. The residual cumulative impact is assessed to reduce to negligible as it will decrease the workload on pilots flying at night Summary of Impact The magnitude of impact is assessed as negligible from the proposed development on low flying and LFA20(T). The magnitude of cumulative impact is assessed as small. Following mitigation (if deemed necessary), the residual magnitude of impact is assessed as negligible, and the residual magnitude of cumulative impact is assessed as negligible. 6.8 Turnberry Navigation Aid and Brown Carrick Hill Site Analysis Although captured in the search criteria used for this assessment, NERL only safeguards such equipment to a radius of 10km from wind turbines, and even within this radius, effects are normally only significant within say, 5km. This is confirmed by the NERL online self-assessment tool which shows all proposed wind turbines to be outside the safeguarded zone Discussion There are no concerns to be addressed with respect to the Turnberry radio navigation aid or to the Brown Carrick Hill radio communications site Summary of Impact There will be no impact from the proposed development on the Turnberry radio navigation aid or to the Brown Carrick Hill radio site and hence no cumulative impact. 6.9 Airspace and Air Traffic Analysis The impact on airspace can be through obstruction to aerial navigation or through effects on navigation systems. The latter are considered separately so only aerial obstruction issues are considered here Traffic in Controlled Airspace There is no controlled airspace below 5,500ft amsl, more than 4,000ft above the highest turbine. This is well in excess of the most stringent obstacle guidance criteria for safe flight (i.e., for instrument flight rules traffic), so there are no obstacle issues to consider. Linfairn Wind Farm 23 Aviation Impact Assessment

26 Traffic in Uncontrolled Airspace The airspace immediately above and around the proposed wind farm is uncontrolled. Given the high ground in the vicinity, it is extremely unlikely that instrument flight rules (IFR) traffic would have to fly higher than at present near the wind farm, and visual flight rules (VFR) traffic would only need to alter flight profiles or direction when extremely close to the wind farm. Military low flying traffic is considered separately, so is omitted from this discussion Discussion There will be no impact on controlled airspace, and negligible impact on uncontrolled airspace, giving an overall impact magnitude of negligible. There are no wind farms close enough to give any cumulative impact Summary of Impact The magnitude of impact on airspace and air traffic is assessed as negligible. There will be no cumulative impact Summary of Proposed Mitigation Prestwick Airport PSR Radar mitigation is likely to be necessary to avoid an objection from Prestwick Airport. Mitigation technologies expected to be available within the lifetime of a planning consent and acceptable to Prestwick Airport include (but are not necessarily limited to) Aveillant s Holographic Radar, and C-Speed s Lightwave Radar Low Flying and LFA20(T) Consultation with the MoD is on-going (as of November 2014) with regards to appropriate mitigation. It is envisaged that infra-red lighting will be required on a number of turbines to mitigate any potential impacts Other Receptors No mitigation is required for other receptors Overall Impact Summary Prestwick Airport PSR The magnitude of impact on the Prestwick Airport PSR is assessed as small; the magnitude of cumulative impact is assessed as medium. Following mitigation, the residual magnitude of impact is assessed as negligible; the residual magnitude of cumulative impact is assessed as beneficial and medium Low Flying and LFA20(T) The magnitude of impact on low flying and LFA20(T) is assessed as negligible; the magnitude of cumulative impact is assessed as small. Following mitigation (if deemed necessary), the residual magnitude of impact is assessed as negligible, and the residual magnitude of cumulative impact is assessed as negligible Airspace and Air Traffic The magnitude of impact on airspace and air traffic is assessed as negligible. There will be no cumulative impact. Linfairn Wind Farm 24 Aviation Impact Assessment

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