Loch Urr Wind Farm Aviation Impact Assessment

Transcription

1 Loch Urr Wind Farm Aviation Impact Assessment Date: 11th November 2014 Author: Steve Hyam Revision: Issue 1 Osprey Ref: This document is of UK origin and has been prepared by Osprey Consulting Services Limited (Osprey) and, subject to any existing rights of third parties, Osprey is the owner of the copyright therein. The document is furnished in confidence under existing laws, regulations and agreements covering the release of data. This document contains proprietary information of Osprey and the contents or any part thereof shall not be copied or disclosed to any third party without Osprey s prior written consent. Osprey Consulting Services Limited 2014 The Forge, London Road, Bentley, Hampshire. GU10 5HY / enquiries@ospreycsl.co.uk Registered in England and Wales under No:

2 Document Details Reference Document Title Description Loch Urr Wind Farm Aviation Impact Assessment Document Ref Issue Issue 1 Date 11 th November 2014 Client Name Classification Axis PED Ltd Commercial in Confidence Issue Amendment Date Draft A First Draft 3 rd June 2014 Draft B Update based on design freeze 22 nd August 2014 Draft C Client Comments Addressed 20 th October 2014 Draft D Further Comments Addressed 30 th October 2014 Issue 1 Document Issued 11 th November 2014 Approval Level Authority Name Author Osprey CSL Steve Hyam Internal Approval Osprey CSL Stewart Heald Client 1 Approval Axis PED Ltd Andrew Russell Loch Urr Wind Farm Aviation Impact Assessment Document Details 2

3 Executive Summary E.ON Climate and Renewables UK Developments Ltd, with the support of Planning Consultants Axis PED Ltd (Axis), is proposing the development of the Loch Urr Wind Farm. The development is expected to consist of up to 26 turbines at a maximum anticipated blade tip height of metres (m). Initial consultation on a previous turbine layout at the Loch Urr site led to the indication of a National Air Traffic Services (NATS) objection as a result of theoretical detectability of the turbines by the NATS Great Dun Fell and Lowther Hill Primary Surveillance Radar (PSR) systems. In addition, Axis has requested analysis on the potential for the development to have an effect on Military Low Flying operations in the region. Operational Impact National Air Traffic Services The Loch Urr turbines are theoretically likely to be detectable by the NATS Lowther Hill and Great Dun Fell PSR systems and would present an area of turbine induced radar clutter on radar displays. The provision of Air Traffic Services by NATS will be impacted in the area of the Wind Farm and therefore NATS are likely to be concerned that they may be unable to provide the requisite separation standards between the wind farm clutter and aircraft traffic operating in the CAS. Initial consultation with NATS has confirmed the extent of the potential effect of the Wind Farm on their operations. NATS has indicated during consultation that the effects of the Wind Farm could be technically mitigated by the implementation of a Project Raytheon Modification (Project RM) upgrade to the Great Dun Fell PSR. In addition, Osprey analysis has concluded that a similar upgrade to the NATS Lowther Hill PSR would also mitigate the effect of the development on this radar system. Ministry of Defence (MOD) Low Flying The proposed turbines would be located within Low Flying Area (LFA) 16 and Tactical Training Area (TTA) 20T, which are considered by the MOD to be high priority low flying training areas. Initial consultation in 2011 indicated that the MOD had no concerns with the proposal. The response from the MOD stated a requirement that in the interests of air safety that a number of the turbines are fitted with a form of aviation obstruction lighting for day and night operations. The lighting of the turbines with the requested aviation obstruction lighting, combined with adherence to the notification requirements detailed at Section 1, is likely to be sufficient to mitigate the safety hazard to low-flying aircraft in the vicinity of the Wind Farm. Recommendations The following recommendations should be considered by E.ON: Further consultation with NATS to agree the process regarding the Project RM (Raytheon Modification) implementation strategy to mitigate the effects of the Loch Urr Wind Farm; and Loch Urr Wind Farm Aviation Impact Assessment Executive Summary 3

4 Further consultation is required to agree the finalised lighting requirements to mitigate the effect on Military Low Flying activities. Loch Urr Wind Farm Aviation Impact Assessment Executive Summary 4

5 Table of Contents 1 Introduction General Background Purpose, Methodology and Scope Document Structure Loch Urr Wind Farm Overview Wind Farm Location and Coordinates Radar Footprint Aviation Baseline Environment Overview National Air Traffic Services Overview Radar LOS Analysis Operational Impact Analysis Technical Mitigation Capability NATS Analysis Conclusions MOD Low Flying Overview UKLFS Dimensions and Uses Impact on Low Flying Operations MOD Consultation MOD Low Flying Conclusions Other Considerations Glenswinton Airstrip Conclusions and Recommendations NATS Analysis Conclusions MOD Low Flying Conclusions Other Considerations Recommendations References Loch Urr Wind Farm Aviation Impact Assessment Table of Contents 5

6 Table of Figures Figure 1 Map of Loch Urr development area, extracted from a map provided by Axis Figure 2 Cross Sectional View of Airspace Structure Figure 3 Terrain Elevation profile Lowther Hill PSR to Loch Urr Turbine Figure 4 Terrain Elevation profile Great Dun Fell PSR to Loch Urr Turbine Figure 5 Loch Urr in relation to the Scottish TMA (hashed line) and adjoining Civil Airway structure (not to scale) Figure 6 Loch Urr in relation to Upper Air Routes (not to scale) Table of Tables Table 1.1 Identified Aviation Stakeholders... 7 Table 1.2 Qualitative Definitions of LOS results... 9 Table 2.1 Loch Urr Turbine Coordinates Table 4.1 Theoretical Base of Lowther Hill PSR Project RM coverage over Loch Urr Wind Farm Table 8.1 Table of References Loch Urr Wind Farm Aviation Impact Assessment Table of Contents 6

7 1 Introduction 1.1 General E.ON Climate and Renewables UK Developments Ltd with the support of Planning Consultants Axis PED Ltd (Axis), is proposing the development of the Loch Urr Wind Farm. The development is expected to consist of up to 26 turbines at a maximum anticipated blade tip height of metres (m). The development site is situated approximately 7 kilometres (km) southwest of the town of Moniaive in Dumfries and Galloway, Scotland. Initial consultation on a previous turbine layout at the Loch Urr site, lead to the indication of a National Air Traffic Services (NATS) objection as a result of the theoretical detectability of the turbines by the NATS Great Dun Fell and Lowther Hill Primary Surveillance Radar systems (PSRs). Axis has requested an analysis of the new layout with respect to the likelihood of this receiving an objection from NATS. In addition, Axis has requested analysis on the potential for the development to have an effect on Military Low Flying operations in the region. This document presents the results of an Aviation Impact Assessment (AIA) of the proposal to construct the Wind Farm. This assessment was completed in accordance with Civil Aviation Authority (CAA) guidance in Civil Aviation Publication (CAP) 764 [Reference 1]. In accordance with the scope of works, the Wind Farm was assessed with regard to the potential to affect the Aviation Stakeholders listed in Table 1.1 below. No other Aviation Stakeholders were considered to have the potential to be affected by the proposed development. Table 1.1 Identified Aviation Stakeholders Stakeholder Type Approximate Distance Approximate Bearing to wind farm NATS Lowther Hill Civil En-Route Radar 28 km 205 NATS Great Dun Fell Civil En-Route Radar 107 km 300 MOD Low Flying Low Flying Area 16 and Tactical Training Area 20T N/A N/A 1.2 Background The effects of wind turbines on aviation interests have been widely publicised but the primary concern is one of safety. There are innumerable subtleties in the actual effects but there are two dominant scenarios that may lead to objections from aviation stakeholders: Loch Urr Wind Farm Aviation Impact Assessment Introduction 7

8 1. Physical: Turbines can present a physical obstruction at or close to an aerodrome; and 2. Radar/Air Traffic Services (ATS): Turbine clutter appearing on radar displays can affect the safe provision of ATS as it can mask unidentified aircraft from the air traffic controller and/or prevent the controller from accurately identifying aircraft under control. In some cases, radar reflections from the turbines can affect the performance of the radar system itself. 1.3 Purpose, Methodology and Scope Purpose This assessment considers the impact of the turbines once they are fully installed and does not consider any safety issues relating to the construction, installation or through life support of the turbines on the site. However, Osprey recommends that the developer consider the information in this report when assessing the safety of any installation, construction or maintenance phases with respect to aviation interests Notification and Lighting Requirements Tall slender constructions such as wind turbines or anemometer masts, despite their size, can be difficult to see from the air in certain weather conditions. Guidance has been issued by RenewableUK [Reference 2], which recommends that to facilitate safe visual flight, day or night, in the vicinity of anemometer masts and/or turbines: Information regarding construction should be passed to the Defence Geographic Centre (DGC) and the General Aviation Awareness Council (GAAC) at least 6 weeks in advance of the erection or removal of an anemometer mast or first turbine and to follow up on the day with a confirmation that the activity has taken place; o o o Data should include location, height (of all structures over 150 feet (ft)), date of erection, date of removal and lighting type (none, infrared or lighting brightness); Local aerodromes identified during consultation should be notified, particularly any police helicopter or air ambulance unit; 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 site construction and any associated lighting (where applicable), for example, the height and temporary location of construction cranes be provided to the UK Aeronautical Information Service (NATS AIS) for promulgation in applicable aviation publications including the UK Integrated Aeronautical Information Package (UK IAIP) [Reference 3]. Other relevant existing legislation regarding land-based obstacles to air navigation includes the following: Obstacles close to licensed aerodromes: Section 47, Civil Aviation Act 1982; Obstacles close to government aerodromes: Town and Country Act, (Government permitted development) Order 2000; and Loch Urr Wind Farm Aviation Impact Assessment Introduction 8

9 Lighting of land-based tall structures (outside of aerodrome safeguarded areas): Article 219, Air Navigation Order 2014 (CAP 393) Radar Line of Sight (LOS) Analysis and Caveat Osprey used the ATDI ICS LT 1 (Version 3.7.7) tool to model the terrain elevation profile between the identified radar systems and the Loch Urr Wind Farm. Otherwise known as a point-to-point LOS analysis the result is a graphical representation of the intervening terrain and the direct signal LOS (taking into account earth curvature and radar signal properties). Caveat: This is a limited and theoretical desk based study; in reality there are unpredictable levels of signal diffraction and attenuation within a given radar environment (ambient air pressure, density and humidity) that can influence the probability of a turbine being detected. Our analysis is designed to give an indication of the likelihood of the turbine being detected such that the operational significance of the turbine relative to nearby aviation assets can be assessed. The qualitative definitions used in our assessment are defined in Table 1.2 below. Table 1.2 Qualitative Definitions of LOS results Result Yes Likely Unlikely No Definition the turbine is highly likely to be detected by the radar: direct LOS exists between the radar and the turbine the turbine is likely to be detected by the radar at least intermittently the turbine is unlikely to be detected by the radar but cannot rule out occasional detection the turbine is unlikely to be detected by the radar as significant intervening terrain exists The complete set of LOS results are contained in Axis Loch Urr Report LOS Diagrams Issue 2 attached with this assessment Operational Analysis For licensed and military aerodromes, Osprey makes use of published procedures in the UK IAIP [Reference 3] and Military Aeronautical Information Publication (AIP) [Reference 4] as appropriate as well as our extensive experience of the applicable regulatory requirements for the safe provision of air traffic control services in carrying out our assessment. For unlicensed aerodromes, Osprey analysts use their knowledge of the regulations and operational experience to apply the expected safeguarding standards to unlicensed airfields. We will also take into consideration 1 Advanced Topographic Development and Images Ltd ICS Lite Version Loch Urr Wind Farm Aviation Impact Assessment Introduction 9

10 information regarding obstacles and procedures published by unlicensed airfields i.e. through their websites or safeguarding maps lodged with the Local Planning Authorities. One of our Air Traffic Control (ATC) experts, who have several decades of active service between them and who are highly respected in their field, oversees every assessment of this type carried out by Osprey. 1.4 Document Structure The document utilises the following structure: Section 1 (this section) gives an introduction to the report; Section 2 introduces the Loch Urr Wind Farm and its parameters; Section 3 gives an outline of the existing airspace structure in the region of the development; Section 4 studies the effect of the development on NATS radar, operations and infrastructure and considers technical mitigation capability; Section 5 analyses the potential for impact on MOD Low Flying operations in the region; Section 6 gives an indication of the effect on other stakeholder interests; and Section 7 gives the conclusions and recommendations and is followed by a list of references used throughout the analysis. Loch Urr Wind Farm Aviation Impact Assessment Introduction 10

11 2 Loch Urr Wind Farm 2.1 Overview The Loch Urr Wind Farm development is expected to consist of up to 26 turbines at a maximum anticipated blade tip height of m above ground level (agl) and is situated approximately 7 km southwest of the town of Moniaive in Dumfries and Galloway, Scotland. 2.2 Wind Farm Location and Coordinates Figure 1 illustrates the extent of the developable area (red line boundary) with an indicative turbine development located within. Figure 1 Map of Loch Urr development area, extracted from a map provided by Axis Reproduced from Ordnance Survey data. HMSO Crown Copyright Reserved. Licence number Loch Urr Wind Farm Aviation Impact Assessment Loch Urr Wind Farm 11

12 Table 2.1 provides the coordinates for each individual turbine of the proposed Loch Urr Wind Farm. Table 2.1 Loch Urr Turbine Coordinates Ref Easting Northing Ref Easting Northing Radar Footprint Based on the coordinates above, the physical size of the Loch Urr Wind Farm on the ground is approximately 3.9 km (northwest-southeast) by 1.65 km (northeastsouthwest). Assuming a nominally accepted 100 m 2 wide margin for unwanted radar returns either side of a single turbine, the potential size of the Wind Farm footprint as represented on a typical PSR display system is around 4.1 km by 1.85 km. Therefore, the radar footprint of the Loch Urr Wind Farm would equal an approximate total area of 7.58 km 2 (2.22 NM 2 ). 2 This is an estimate; the size of the clutter will depend on range and the specific operating parameters of the radar (e.g. range-azimuth cell size) i.e. the clutter could appear larger at a greater range from the radar. Loch Urr Wind Farm Aviation Impact Assessment Loch Urr Wind Farm 12

13 3 Aviation Baseline Environment 3.1 Overview The pictorial representation of the cross-section view of the airspace in the vicinity of and above the Loch Urr Wind Farm is shown in Figure 2: Figure 2 Cross Sectional View of Airspace Structure The airspace is categorised as follows: Class G uncontrolled airspace up to Flight Level (FL) 85 (approximately 8,500 feet (ft) above mean sea level (amsl)); any aircraft can operate in this area of uncontrolled airspace without any requirement to be in communication with any ATC Unit. Pilots of aircraft operating in Class G airspace are ultimately responsible for seeing and avoiding other aircraft; Class A Controlled Airspace (CAS) established from FL 85 up to FL 195; aircraft operating within this airspace must be in receipt of an air traffic service (ATS) from NATS Prestwick Centre. The air traffic controller is responsible for maintaining typically 5 NM lateral separation between aircraft; Class C CAS established from FL 195 up to FL 245; all aircraft operating in this airspace must be in receipt of an ATS from NATS or Military controllers located at a NATS control centre; and Loch Urr Wind Farm Aviation Impact Assessment Aviation Baseline Environment 13

14 Class C CAS established above FL 245; again all aircraft operating in this airspace must be in receipt of an ATS from NATS or Military controllers located at a NATS control centre. In addition, the proposed turbines would be located within Low Flying Area (LFA) 16, the largest in the UK and covers mainland Scotland north of the Central Region, the Western Isles, Orkney and Shetland. Furthermore, the development would also be located within Tactical Training Area 20T, when this area is activated (See Section 5 for further information). Loch Urr Wind Farm Aviation Impact Assessment Aviation Baseline Environment 14

15 4 National Air Traffic Services 4.1 Overview National Air Traffic Services (NATS) Ltd provides ATS at some airports in the UK and to traffic en-route within UK airspace. NATS operate a number of long range PSR and Secondary Surveillance Radar (SSR) positioned to provide maximum coverage of UK airspace. Additionally, military controllers operate at NATS ATCCs. In conjunction with their civilian counterparts, they manage the coordination between civilian and military flights. Other ATS providers, such as the MOD and airports, also use surveillance data from NATS radar assets. NATS has a licence obligation to provide these services to a high quality and performance standard for the benefit of UK aviation as a whole. Any effect the proposed development might have on NATS radars must be considered both in terms of effect on the civilian and military enroute services and in the context of its remote users. The Wind Farm is located on a bearing of 205 from the Lowther Hill PSR at a range of approximately 28 km (15 NM). Furthermore, it is located on a bearing of 300, and is at a range of approximately 107 km (58 NM) from the Great Dun Fell PSR. 4.2 Radar LOS Analysis Lowther Hill PSR Figure 3 presents the theoretical radar LOS terrain elevation profile between the NATS Lowther Hill PSR (left of the diagram) and the blade tip height of Loch Urr Turbine 1 at m (right of the diagram). Figure 3 Terrain Elevation profile Lowther Hill PSR to Loch Urr Turbine 1 Figure 3 indicates this turbine is highly likely to be detectable by the radar; direct LOS exists between the radar and the turbine. The result is indicative of the results for all proposed Loch Urr turbines except Turbine 26, which is expected to be intermittently detectable by this PSR. Loch Urr Wind Farm Aviation Impact Assessment National Air Traffic Services 15

16 4.2.2 Great Dun Fell PSR Figure 4 presents the theoretical radar LOS terrain elevation profile between the NATS Great Dun Fell PSR and the m blade tip height of Loch Urr Turbine 1. Figure 4 Terrain Elevation profile Great Dun Fell PSR to Loch Urr Turbine 1 Figure 4 indicates this turbine is highly likely to be detectable by the radar; direct LOS exists between the radar and the turbine. The result is indicative of the results for all proposed Loch Urr turbines except for three turbines, which are expected to be intermittently detectable by this PSR (Turbines 12, 13 and 18). 4.3 Operational Impact Analysis The Wind Farm would be located beneath Controlled Air Space (CAS), adjacent to the Scottish Terminal Control Area (TMA), which is utilised for the protection of flights into and out of the major airports in the central belt of Scotland (Edinburgh, Glasgow and Prestwick Airports). The Wind Farm development is located beneath CAS, which is established above a minimum of FL 85 (approximately 8,500 ft amsl). CAS is considered as a known traffic environment (all air traffic within this airspace is required to be in communication with Air Traffic Control (ATC)). Osprey has identified that aircraft operating in the airspace will follow routings that would position aircraft in close proximity to the clutter that would be associated with the Wind Farm. The possibility exists that aircraft, undetected by the PSR, could operate over the area of the proposed turbines. Consequently, the provision of ATS by NATS will be affected, and therefore NATS would have to ensure that aircraft avoid the wind farm clutter in which undetected aircraft may be operating, by the required 5 NM separation standard. NATS response to initial consultation indicated that the turbine development parameters would be detectable by both the Lowther Hill and Great Dun Fell PSR systems and present as an unacceptable impact on NATS operations [Reference 5]. Figure 5 shows the Wind Farm in relation to the Scottish TMA and the adjoining civil airways structure below FL 195. Loch Urr Wind Farm Aviation Impact Assessment National Air Traffic Services 16

17 Figure 5 Loch Urr in relation to the Scottish TMA (hashed line) and adjoining Civil Airway structure (not to scale) Reproduced from CAA digital map data Crown copyright UK IAIP ENR NATS also has responsibility for the provision of ATS to aircraft operating on the upper air routes above FL 195. Aircraft in transit uses these routes across UK airspace between Continental Europe, UK airports and North America. Figure 6 shows the Wind Farm in relation to these upper air routes. Figure 6 Loch Urr in relation to Upper Air Routes (not to scale) Reproduced from CAA digital map data Crown copyright UK IAIP ENR Loch Urr Wind Farm Aviation Impact Assessment National Air Traffic Services 17

18 4.4 Technical Mitigation Capability Further correspondence from NATS in May 2013 [Reference 6] indicated that the development would benefit from the implementation of a Project Raytheon Modification (Project RM) upgrade to the NATS Great Dun Fell PSR. However, no indication has been received regarding the potential for this mitigation to also be used for the Lowther Hill PSR NATS Project Raytheon Modification (Project RM) NATS in conjunction with the supplier of their PSR systems, Raytheon, are in a process of developing a technical solution so that clutter generated by wind turbines can be removed from a controllers display whilst ensuring that the current ability to detect, track and provide navigational assistance to aircraft is not degraded. Two key criteria need to be met in order for the mitigation to be successful: 1. The wind turbines must be further than 9 NM from the radar; and 2. Aircraft must be flying greater than 1.2 or higher in elevation above the blade tips. These criteria mean that a case-by-case assessment is required by NATS to determine if the Project RM would provide an adequate base of radar cover in the vicinity of the Wind Farm. Analysis concluded that the development is also considered to be detectable by NATS Lowther Hill PSR, so an assessment has been conducted to establish the capability of implementing a Project RM upgrade to this PSR to mitigate the potential effects of the Loch Urr Wind Farm. A number of the proposed Loch Urr turbines were assessed to analyse the potential for the site to benefit from this mitigation capability to the Lowther Hill PSR system. The results of the analysis of the current proposed Loch Urr layout utilising Project RM criteria for the Lowther Hill PSR are shown below in Table 4.1. Table 4.1 Theoretical Base of Lowther Hill PSR Project RM coverage over Loch Urr Wind Farm Turbine Reference Range from Lowther Hill Anticipated Base of Radar Coverage (amsl) 1.2 above turbine tip height km/16.6 NM 3,380 ft km/15.9 NM 3,310 ft km/16.2 NM 3,380 ft km/16.9 NM 3,620 ft km/16.1 NM 3,280 ft km/16.8 NM 3,210 ft Loch Urr Wind Farm Aviation Impact Assessment National Air Traffic Services 18

19 Osprey analysis indicates that the potential base of PSR coverage that may exist, should a Project RM upgrade to the Lowther Hill PSR be considered, is approximately 3,620 ft amsl. The established base of CAS above the wind farm is FL 85 (approximately 8,500 ft amsl); therefore, the Loch Urr Wind Farm is in a location that is likely to benefit from a Project RM upgrade to the Lowther Hill PSR. Note: This Project RM analysis was completed using estimated Above Ordnance Datum (AOD) measurements. 4.5 NATS Analysis Conclusions Operational Impact The Loch Urr turbines are theoretically likely to be detectable by the NATS Lowther Hill and Great Dun Fell PSR systems and would present an area of turbine-induced radar clutter on radar displays. The Wind Farm development is located beneath CAS, which is established for the protection of flight into the airports of the Scottish central belt and the upper air routes which are used by aircraft transiting UK airspace. The provision of ATS by NATS will be impacted in the area of the Wind Farm and therefore NATS are likely to be concerned that they may be unable to provide the requisite separation standards between the wind farm clutter and aircraft operating in the CAS. Consultation with NATS has confirmed the extent of the potential effect of the Wind Farm on their operations Technical Mitigation Capability NATS has indicated that the effects of the Loch Urr Wind Farm would be technically mitigated by the implementation of a Project RM upgrade to the Great Dun Fell PSR. In addition, Osprey analysis has concluded that a similar upgrade to the NATS Lowther Hill PSR would also mitigate the effect of the development on this radar system. It is recommended that E.ON continue to consult with NATS to agree the process regarding the Project RM implementation strategy to mitigate the effects of the Loch Urr Wind Farm on both PSRs should consent be granted. Loch Urr Wind Farm Aviation Impact Assessment National Air Traffic Services 19

20 5 MOD Low Flying 5.1 Overview Low flying is an extremely 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 jet, transport aircraft and helicopters as they support forces on the ground. 5.2 UKLFS Dimensions and Uses The UKLFS covers the open airspace of the whole UK and surrounding overseas areas outside of major cities, towns and specific avoidance areas, from surface to 2,000 ft agl or above mean sea level (amsl). Additionally, there are three areas, known as Tactical Training Areas (TTA), which are considered suitable for flying lower than the standard training heights due to their challenging terrain and generally sparse population. The capability of Low Flying training in the TTAs allows aircrews to enhance their skills in preparation for deployment on operations. Height in the UKLFS is 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 ground based object. Military fixed-wing aircraft are deemed to be low flying if they are less than 2,000 ft MSD and can operate down to 250 ft MSD; light propeller driven aircraft and helicopters are low flying below 500 ft MSD. In the TTAs, fast-jets can fly at 100 ft MSD and helicopters can fly down to 100 ft agl or down to ground level. Hercules aircraft can fly at 150 ft MSD in the TTAs. 5.3 Impact on Low Flying Operations The proposed Wind Farm would be located within Low Flying Area (LFA) 16 and within TTA 20T, when the area is active. These areas are located in the south of Scotland, including the Borders Region, Dumfries and Galloway and other counties up to and including those within the central belt of Scotland. LFA 16 and TTA 20T are considered by the MOD to be areas of key importance for military low flying training due to the challenging terrain and sparse population within the area. In addition, the area has a high incidence of unrestricted airspace above 2,000 ft, which gives increased flexibility to military aircraft to enter and leave the Low Flying environment, and better than average weather conditions. Additionally, the areas are close to the Army Field training centre at Otterburn, and they border the Electronic Warfare Tactics Range at RAF Spadeadam. The site would be located in an important and busy area for low flying training, thereby potentially having a detrimental impact on that training for military aircrews due to obstacle hazards and the inability for crews to fly as low as they can currently. Loch Urr Wind Farm Aviation Impact Assessment MOD Low Flying 20

21 Aircraft completing low flying training in these areas would be considered to be operating in visual meteorological conditions (VMC 3 ). This means that aircraft will be operating in weather conditions in which pilots would have sufficient visibility to fly the aircraft, maintaining visual separation from terrain, obstacles and other aircraft. Furthermore, such aircraft must also carry appropriate mapping detailing the relevant terrain and any obstacles; this mapping would display the Wind Farm in the event of it being constructed. 5.4 MOD Consultation The MOD response received by E.ON in July 2011 to initial consultation indicated that the MOD had no concerns with the proposed Wind Farm. However, the response had a caveat that stated that the analysis was based on the level of wind energy development at the time of the original consultation, and that should other wind farms be consented or built in the vicinity prior to Loch Urr being submitted for planning approval, their position may change. In addition, the MOD stated a requirement in the interests of air safety, that the corner most turbines and 6 other turbines within the proposed development are fitted with a form of aviation obstruction lighting for day and night operations [Reference 7]. 5.5 MOD Low Flying Conclusions The proposed turbines would be located within LFA 16 and TTA 20T which are considered by the MOD to be high priority low flying training areas. Initial consultation in 2011 indicated that the MOD had no concerns with the proposal. E.ON have finalised the turbine number and parameters, concluding in a lesser number of turbines; consequently, the development is considered not to present an increased effect on MOD Low Flying operations to that what was assessed by the MOD in The initial response from the MOD stated a requirement that in the interests of air safety that a number of the turbines are fitted with a form of aviation obstruction lighting for day and night operations [Reference 7]. It may be possible to negotiate the use of Infra-Red lighting only (invisible to the naked eye) should landscape and visual impact of red lighting be considered unacceptable. The lighting of the turbines with the requested aviation obstruction lighting, combined with adherence to the notification requirements detailed at Section 1, is likely to be sufficient to mitigate the safety hazard to low-flying aircraft in the vicinity of the Wind Farm. 3 VMC: Conditions in which pilots have sufficient visibility to fly the aircraft maintaining visual separation from terrain, obstacles and other aircraft. Loch Urr Wind Farm Aviation Impact Assessment MOD Low Flying 21

22 6 Other Considerations 6.1 Glenswinton Airstrip Glenswinton is small, unlicensed airstrip located approximately 13 km to the northwest of Castle Douglas, owned and operated by Glenswinton Farm. The Airstrip has a compacted gravel runway measuring approximately 430 m in length and 15 m in width. The aviation operations from this airstrip will be completed under Visual Flight Rules (VFR) 4 in reasonable weather conditions (i.e. VMC). Under these conditions, pilots can reasonably be expected to be observing CAP 393 (Rules of the Air) [Reference 8], which state that an aircraft shall not be flown closer than 500 ft to any person, vessel, vehicle or structure. At a range of approximately 10 km, the Wind Farm would be well outside the lateral limit of any physical safeguarding criteria of an aerodrome of this size and intended operation. The Loch Urr Wind Farm is considered not to directly affect aviation operations at the Glenswinton Airstrip. 4 VFR: Visual Flight Rules are a set of regulations under which a pilot operates an aircraft in weather conditions clear enough to allow the pilot to see where the aircraft is going with visual reference to the ground and avoiding obstacles and other aircraft. Loch Urr Wind Farm Aviation Impact Assessment Other Considerations 22

23 7 Conclusions and Recommendations 7.1 NATS Analysis Conclusions The Loch Urr turbines are theoretically likely to be detectable by the NATS Lowther Hill and Great Dun Fell PSR systems and would present an area of turbine-induced radar clutter on radar displays. The Wind Farm development is located beneath CAS, which is established for the protection of flight into the airports of the Scottish central belt and the upper air routes which are used by aircraft transiting UK airspace. The provision of ATS by NATS will be impacted in the area of the Wind Farm and therefore NATS are likely to be concerned that they may be unable to provide the requisite separation standards between the wind farm clutter and aircraft traffic operating in the CAS. Consultation with NATS has confirmed the extent of the potential effect of the Wind Farm on their operations. Through consultation, NATS has indicated that the effects of the Loch Urr Wind Farm could be technically mitigated by the implementation of a Project RM upgrade to the Great Dun Fell PSR. In addition, Osprey analysis has concluded that a similar upgrade to the NATS Lowther Hill PSR would also mitigate the effect of the development on this radar system. 7.2 MOD Low Flying Conclusions The proposed turbines would be located within LFA 16 and TTA 20T which are considered by the MOD to be high priority low flying training areas. Initial consultation in 2011 indicated that the MOD had no concerns with the proposal. E.ON have finalised the turbine number and parameters, concluding in a lesser number of turbines; consequently, the development is considered not to present an increased effect on MOD Low Flying operations to that what was assessed by the MOD in The initial response from the MOD stated a requirement that in the interests of air safety that a number of the turbines are fitted with a form of aviation obstruction lighting for day and night operations [Reference 7]. It may be possible to negotiate the use of Infra-Red lighting only (invisible to the naked eye) should landscape and visual impact of red lighting be considered unacceptable. The lighting of the turbines with the requested aviation obstruction lighting, combined with adherence to the notification requirements detailed at Section 1, is likely to be sufficient to mitigate the safety hazard to low-flying aircraft in the vicinity of the Wind Farm. 7.3 Other Considerations Glenswinton Airstrip is a small unlicensed airstrip located approximately 10 km from Loch Urr Wind Farm. At this range the Wind Farm would be well outside the lateral limit of any physical safeguarding criteria of an aerodrome of this size and intended operation. The operations from the airstrip would be in good weather conditions with any pilot being responsible for seeing and avoiding other aircraft or Loch Urr Wind Farm Aviation Impact Assessment Conclusions and Recommendations 23

24 obstacles. The Loch Urr Wind Farm is considered not to directly affect aviation operations at the Glenswinton Airstrip. 7.4 Recommendations The following recommendations should be considered by E.ON: Further consultation with NATS to agree the process regarding the Project RM implementation strategy to mitigate the effects of the Loch Urr Wind Farm; and Further consultation is required to agree the finalised lighting requirements to mitigate the effect on Military Low Flying activities. Loch Urr Wind Farm Aviation Impact Assessment Conclusions and Recommendations 24

25 8 References Table 8.1 Table of References Reference Name Origin 1 CAP 764: Policy and Guidelines on Wind Turbines Fifth Edition June Guidance on Low Flying Aircraft and Onshore Tall Structures Including Anemometer Masts and Wind Turbines. Civil Aviation Authority RenewableUK Dated July UK Integrated Aeronautical Information Package (UK IAIP) Amended to AIRAC 11/ Military Aeronautical Information Publication (Mil AIP) National Air Traffic Services Ministry of Defence Amended to AIRAC 11/ NATS Technical and Operational Analysis (TOPA) W(F)11396 Dated July NATS Project RM Mitigation Capability Correspondence Dated 16 th May MOD Pre-application Correspondence DE/C/SUT/43/10/1/12311 National Air Traffic Services National Air Traffic Services Ministry of Defence Dated 27 th July CAP 393: Air Navigation The Order and the Regulations Reprinted 12 th May 2014, incorporating amendments to 3/2014 Civil Aviation Authority Loch Urr Wind Farm Aviation Impact Assessment References 25