Wind Farm Aviation Consultants Ltd

Transcription

Wind Farm Aviation
Consultants Ltd
AEE Renewables Ltd – Proposed
Solar Energy Facility, Burton
Farm, Lincoln
Our Reference: WFAC/AAE/BURTON/05/14
Authors - Commander Shane Savage BSc, Royal Navy (Retd)
Sqn Ldr Mike Hale MBE, MSc RAF (Retd)
Wind Farm Aviation Consultants Ltd, Company No.: 077761599
E-mail: [email protected] Tel.: +44 (0)1326 560379 Mobile: +44 (0)750 8229969
www.wfac-ltd.co.uk
The information contained within this document (including all graphs, maps, tables, images and photographs) is,
and remains, the copyright of Wind Farm Aviation Consultants Ltd © 2014, and is for the sole use of the
addressee and may not be reproduced by any means, without the explicit written permission of Wind Farm
Aviation Consultants Ltd.
AEE Renewables Ltd – Proposed Solar Energy Facility, Burton Farm, Lincoln
Our Ref: WFAC/AAE/BURTON/05/14
Contents
Reference Documents .................................................................................................................................... 2
Scope .............................................................................................................................................................. 2
Executive Summary....................................................................................................................................... 3
Background .................................................................................................................................................... 4
Glare Modelling............................................................................................................................................. 4
The Proposed Site .......................................................................................................................................... 5
The General Area........................................................................................................................................... 5
Background .................................................................................................................................................... 6
Section 1 - Physical Safeguarding ................................................................................................................. 6
Technical Safeguarding ................................................................................................................................. 7
Section 3 - Glint and Glare – Visual Impact ................................................................................................. 8
UK Guidance ................................................................................................................................................. 8
Definitions.................................................................................................................................................... 10
UK Experience ............................................................................................................................................. 15
Manchester Boston Airport ......................................................................................................................... 15
Glare Modelling in the vicinity of Scampton ............................................................................................. 16
For Array 2: .................................................................................................................................................. 26
RAF Scampton ............................................................................................................................................. 27
Scampton Visual Circuits ............................................................................................................................ 27
The Red Arrows........................................................................................................................................... 28
Sunlight Reflection from the Solar Park at Scampton ............................................................................... 29
Glint and Glare Conclusions ....................................................................................................................... 33
Overall Conclusions .................................................................................................................................... 34
Additional Sources: ..................................................................................................................................... 35
Acronyms ..................................................................................................................................................... 36
Glossary of Terms ........................................................................................................................................ 38
PROFESSIONAL QUALIFICATIONS AND EXPERIENCE ................................................................ 41
Cdr Shane Savage BSc, RN (Retd) .......................................................................................................... 41
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Copyright Wind Farm Aviation Consultants Ltd © 2014
Registered Company No: 077761599
Commercial-in-Confidence
Reference Documents
A. Civil Aviation Rules of the Air Regulations
B. CAP 168 Licensing of Aerodromes, April 2011
C. CAP 774 UK Flight Information Services
D. CAP 738 Safeguarding of Aerodromes
E. CAP 793 Safe Operating Practices at Unlicensed Aerodromes
F. CAP 493 Manual of Air Traffic Services Part 1
G. CAP 670
H. CAP 660 - Parachuting
I.
UK Aeronautical Information Publications (AIP)
J.
CAA 1:250,000 and 1:500,000 VFR Charts
K. Joint MoD/CAA Wind Farm Interim Guidelines
L. National Planning Policy Framework
Scope
Wind Farm Aviation Consultants Ltd have been tasked with writing a site assessment on the
aviation issues relating to the construction and operation of a solar power development at
Burton Farm, Lincoln in accordance with the consultation criteria specified within this
report.
WFAC will not be held liable for any loss/damage incurred through the use of the contents
of this report.
2
Executive Summary
Wind Farm Aviation Consultants Limited (WFAC) were instructed by AEE Renewables to
carry out a glare assessment for a proposed solar development on land near to RAF
Scampton.
There are no physical safeguarding implications resultant from the proposed development.
There should be no safeguarding implications for the communications at RAF Scampton as a
result of the construction of the solar farm.
There is no basis in aviation safeguarding regulation or guidance for the refusal of the
application.
There is no evidence to support any statement that the solar farm will cause any visual
impact on pilots flying from or in the vicinity of RAF Scampton airfield.
As a result of modelling of solar glare in accordance with Federal Aviation Authority
recommended procedures, potential periods of glare may occur in early morning and late
afternoons for limited periods in Spring and late Summer; any glare experienced is not
considered to be significant in terms of aviation.
In WFAC’s view there are no implications under the requirements of the UK Air Navigation Order as a result of the proposed development.
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Background
AAE renewables Ltd are proposing to construct a photovoltaic (PV) solar array immediately
to the north-west of Lincoln, at Burton Farm. The proposal consists of a number of PV
panels facing due south (relative to True North) inclined at an angle of 20° to the horizontal.
The development will be approximately 4km south of RAF Scampton.
Glare Modelling
The US Federal Aviation Authority are the leading authorities in solar arrays around
airports and have undertaken further research to validate their previous Technical Guidance
They have developed a software tool, in conjunction with industry, to answer two
fundamental questions pertaining to glare from solar PV installations:
Will glare occur (where and when), and,
If glare occurs, what is the potential ocular impact?
The modelling tool determines when and where solar glare can occur throughout the
year from a user-specified PV array as viewed from user-prescribed observation points
and on final approach to runways. The potential ocular impact from the observed glare
is also determined.
Latitude and Longitude are automatically recorded providing
necessary information for sun position and vector calculations. Additional information
regarding the orientation and tilt of the PV panels, reflectance, environment and ocular
factors are entered by the User.
If glare is found, the tool calculates the retinal irradiance and subtended angle
(size/distance) of the glare source to predict potential ocular hazards ranging from
temporary after-image to retinal burn. The results are presented in a simple, easy-tointerpret plot that specifies when glare will occur throughout the year, with colour codes
indicating the potential ocular hazard. The model can also predict relative energy
production while evaluating alternative designs, layouts, and locations to identify
configurations that maximize energy production while mitigating the impacts of glare.
The software is recommended by the FAA for glare hazard analyses near airports; Wind
Farm Aviation Consultants Ltd (WFAC) are Registered Users in the UK and with
permissions to use the derived data in the public domain outside of the United States.
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The Proposed Site
Figure 1 – location of the proposed Burton Farm development
The General Area
The area in which the development is located is close to some of the busiest airspace in
the country, Burton Farm is within the overlapping Military Air Traffic Zones (MATZ)
at the RAF bases at Scampton and Waddington and within Lincolnshire Area of Intense
Aerial Activity. The MATZ surrounding Waddington and Scampton are circles radii
five miles from surface to 3000ft with a stub, or pan-handle, aligned along the main
runway approach from 5 to 10 miles and from 1000 to 3000ft; due to nature of the flying
that occurs at Scampton the airfield is surrounded by a further Restricted Area. Within
each MATZ, and surrounding Scampton airfield is an Air Traffic Zone (ATZ) which is in
place around smaller military and some civil airfields and which has to be observed by
all airspace users. This zone can be radius 2 or 2.5 miles, depending on the length of the
runways; both MATZ and ATZ are designed to protect aircraft in the crucial landing
and take-off stages of flight; the Burton Farm location is on the very edge of this ATZ at
Scampton.
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Background
CAA Interim Guidance on the Solar Photovoltaic System is contained in a CAA Circular of
the same title dated 17 December 2010 and draws largely on the experience of the United
States Federal Aviation Authority. For solar energy development off any airfield site it
directs that the Physical safeguarding criteria laid out in various CAA documents should be
followed.
Section 1 - Physical Safeguarding
Guidance for the operation and safeguarding of licensed civil airfields is contained in CAP
168 - Licensing of Aerodromes (April 2011) and for military airfield at Military Aviation
Authority Manual of Aerodrome Design and Safeguarding; the requirements and
stipulations are virtually identical in both.
Figure 4 – Military Airfield Safeguarding Map
Source: Military Aviation Authority Manual of Aerodrome Design and Safeguarding
The Burton Farm site is within the safeguarded area at the edge of the Inner Horizontal
Surface and the Conical Surface; that IHS is 45m above the lowest runway threshold
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elevation at Scampton which is approximately 171ft above mean sea level (52m). The site
elevation varies widely across the available land footprint but even at the highest elevation
(approximately 66m) there can be no physical safeguarding infringement caused by the
proposed panels.
Technical Safeguarding
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Section 3 - Glint and Glare – Visual Impact
Reflection in the form of glare is present in current aviation operations. The existing sources
of glare come from glass windows, auto surface parking, rooftops, and water bodies. At
airports, existing reflecting surfaces may include hangar roofs, surface parking, and glassy
office buildings. To minimize unexpected glare, windows of air traffic control towers and
airplane cockpits are coated with anti-reflective glazing and operators will wear polarized
eye wear. Potential glare from solar panels should be viewed in this context.
UK Guidance
Whilst the UK CAA has only published interim guidance on implications of solar
photovoltaic installations 1 there is a substantial amount of documentation relating to
extensive studies around the globe.
As the interim guidance states, the CAA is seeking to develop its policy on the installation of
Solar Photovoltaic (SPV) Systems and their impact on aviation. In doing so it is relying on
the experience of the United States Federal Aviation Administration (FAA) as, arguably, the
world leaders in this work and certainly the Aviation Authority with the most extensive
experience and which can also draw on the experience of the US Department of Defense.
The FAA guidance is subject to the caveat that it is subject on to on-going assessment,
“NOTE: As of October 23, 2013, the FAA is reviewing multiple sections of the "Technical Guidance for
Evaluating Selected Solar Technologies on Airports" based on new information and field experience,
particularly with respect to compatibility and glare. All users of this guidance are hereby notified that
significant content in this document may be subject to change, and the FAA cautions users against
relying solely on this document at this time. ….”.2
This report relies on FAA approved modelling for glare hazard analyses near airports rather
than relying solely on the contents of either the CAA or FAA guidance.
As the main discussion point in the interim guidance the CAA highlights that at present the
key safety issue is perceived to be the potential (emphasis added) for reflection from SPV to
cause glare, dazzling pilots or leading them to confuse reflections with aeronautical lights.
The guidance draws attention to the requirements of the Air Navigation Order 20093 (more
recently updated 2012) and to the responsibility for developers and Local Planning
Authorities to be cognizant of:
1 CAA Interim CAA Guidance - Solar Photovoltaic Systems dated 17 December 2010
2 FAA, Technical Guidance for Evaluating Selected Solar Technologies on Airports, FAA –ARP-TR-10-1
3 CAP 393 Air Navigation: The Order and the Regulations
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• Article 137 – Endangering safety of an aircraft
• Article 221 – Lights liable to endanger
• Article 222 – Lights which dazzle or distract.
Article 137 states:
“A person must not recklessly or negligently act in a manner likely to endanger an aircraft, or any person in an aircraft.”
Articles 221 and 222 state:
(1) A person must not exhibit in the United Kingdom any light which:
(a) by reason of its glare is liable to endanger aircraft taking off from or landing at an
aerodrome; or
(b) by reason of its liability to be mistaken for an aeronautical ground light is liable to
endanger aircraft.
(2) If any light which appears to the CAA to be a light described in paragraph (1) is exhibited, the
CAA may direct the person who is the occupier of the place where the light is exhibited or who has
charge of the light, to take such steps within a reasonable time as are specified in the direction:
(a) to extinguish or screen the light; and
(b) to prevent in the future the exhibition of any other light which may similarly
endanger aircraft.
(3) The direction may be served either personally or by post, or by affixing it in some conspicuous
place near to the light to which it relates.
(4) In the case of a light which is or may be visible from any waters within the area of a general
lighthouse authority, the power of the CAA under this article must not be exercised except with the
consent of that authority.
and
A person must not in the United Kingdom direct or shine any light at any aircraft in
flight so as to dazzle or distract the pilot of the aircraft.
This report will not discuss whether a solar photovoltaic panel may be classed as a light but
will consider the issues of glare in the spirit of, and in accordance with, current CAA
guidelines.
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Within those considerations, and for clarification, the following should be noted:
1) The safeguarding requirement for Communications, Navigational and Surveillance
equipment has been addressed earlier. There are no safeguarding implications within the
stipulations of CAP 670.
2) The interim guidance states that, at the end of the review currently underway, the CAA
will:
“develop a policy and provide formal guidance material on the installation of SPV, principally
on or in the vicinity of licensed aerodromes but will also include guidance on installations
away from aerodromes (or ‘en-route’)
It qualifies this with:
“ In this context the term “in the vicinity” refers to officially safeguarded aerodromes noted in the Planning Circulars……and a distance of up to 15km from the ‘Aerodrome Reference Point’ or the centre of the longest runway.”
The requirement for the Local Planning Association (LPA) to consult with aerodrome
operators in the event of a solar farm planning application is aimed at licensed and officially
safeguarded airfields/airports. Operators of licensed aerodromes which are not officially
safeguarded and operators of unlicensed aerodromes and sites for other aviation activities
(for example gliding or parachuting) should take steps to protect their locations from the
effects of possible adverse development by establishing an agreed consultation procedure
between themselves and the local planning authority or authorities. This agreement where
established does not constitute an automatic right to object but is merely an aid to further
discussion.
Definitions
The following definitions and descriptions are key to understanding the potential issues:
Photovoltaic Panel – Photovoltaic panels, also known as PV panels, are designed to
absorb solar energy and retain as much of the solar spectrum as possible in order to
produce electricity.
Glint – produced as a direct reflection of the sun in the surface of the PV panel, this is
the potential source of the visual issues regarding viewer distraction.
Glare – a continuous source of brightness relative to diffuse lighting. This not direct
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reflection of the sun but rather a reflection of the bright sky around the sun. Glare is
significantly less intense than glint.
Source: Panoche Valley Solar Farm Project Glint and Glare Study dated 21 May 2010 (Power
Engineers)
Photovoltaic (PV) solar panels are designed to absorb sunlight in order to convert it into
electricity. Monocrystalline silicon wafers, the basic building block of most photovoltaic
solar modules, absorb up to 70 per cent of the sun’s solar radiation in the visible light spectrum.
Solar cells are typically encased in a transparent material referred to as an encapsulant and
covered with a transparent cover film, commonly glass. The addition of these protective
layers further reduces the amount of visible light reflected from photovoltaic modules.
Photovoltaic panels are using the absorbed energy in two ways;
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the panels generate electricity, and
the mass of the panels heat up.
Silicon is naturally reflective. All solar panels are designed with a layer of anti-reflective
material that allows the sunlight to pass through to the silicon but minimizes reflection. This
design results in the dark appearance of the solar panel. Recent generations of panels have
included an anti-reflective material on the outer surface of the glass to further limit sunlight
reflection. The area of the aluminium frame is very thin and therefore reflection from the
aluminium is not a concern.
The amount of sunlight interacting with the solar panel will vary based on geographic
location, time of year, cloud cover, and solar panel orientation. Solar PV panels are designed
to absorb as much daylight as possible to convert to electricity and, therefore, have a lower
level of reflectivity than other surfaces such as window glass. Commercial designs of solar
panel within the UK typically assert that less than 9% of total visible light is reflected by
solar PV panels in comparison to the 17% that is reflected by normal window glass, although
some panels can reflect as little as 2% of the incoming sunlight depending on the angle of the
sun and assuming use of anti-reflective coatings4. Although PPS22 has been superseded by
the National Planning Policy Framework, it is understood that the companion guide to that
document is still in existence and this advises that PV panels have low reflective properties.5
While the amount of light reflected off a surface is important, the nature of the reflected light
is even more important when assessing the potential for flash blindness. One important
characteristic of light to consider is whether the reflected light is “specular” or “diffuse”. Specular reflection reflects a more concentrated type of light and occurs when the surface in
question is smooth and polished. Examples of surfaces that produce specular reflection
include mirrors and still water. Diffuse reflection produces a less concentrated light and
occurs from rough surfaces such as pavement, vegetation, and choppy water. Figure 8
illustrates specular and diffuse reflections. All surfaces in reality produce a mixture of both
types of reflections, but the surfaces are generally dominated by one type. Outside of very
unusual circumstances, flash blindness can only occur from specular reflections. The exact
percentage of light that is specularly reflected from PV panels is currently unknown.
However, because the panels are a flat, polished surface, it is a reasonable assumption that
most of the light is reflected in a specular way and thus is fundamentally different from that
reflected off a rougher surface.
4 (Evergreen Solar 2010 Evergreen Solar; More Electricity. Fact Sheet.)
5 Page 143. Para 3.
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Figure 5: Different Types of Reflection
Source: Harris Miller Miller and Hanson (HMMH)
Colour is important because some colours absorb light and its energy, whereas others reflect
it. Light colours are most reflective (white being the most), whereas dark colours are least
reflective. Figure 9 shows the percentage of sunlight that is reflected from a variety of
common surfaces. The values provided are primarily influenced by colour and include two
different types of solar technologies: PV and Concentrated Solar Power (CSP)6. The colours
of the surface and the percentage of sunlight it reflects is only one-half of the equation; the
other factor is the physical characteristics of the material’s surface. Flat, smooth surfaces will reflect a more concentrated amount of sunlight back to the receiver, which is referred to as
specular reflection. The more a surface is polished, the more it shines. Rough or uneven
surfaces will reflect light in a diffuse or scattered manner and therefore will not be received
by the viewer as brightly.
The following is the scale of reflectivity of surfaces:
6 CSP is irrelevant given the PV panels planned for installation at Burton and is not considered further in this report.
13
Figure 6: Reflectivity characteristics of differing surfaces. Source: HMMH
PV solar panels are amongst the least reflective and on the basis of this scale the reflectivity
that might be expected from the development at Burton Farm would be less than that
expected from the current farmland and on a par with that from the surface of the roof of the
adjacent buildings in the town of Lincoln.
Within the scope of this desk based assessment WFAC have found no evidence to verify the
claim that the installation of a solar farm at Burton Farm would impact on the conduct of
flight from the airfield as a result of visual effects. There is no evidence from pilots with the
FAA or CAA findings or guidance that either types of reflection, glint or glare, can cause a
problem or present a safety issue and the UK has an increasing number of arrays and
developments in the vicinity of airports and military airfields which do not appear to have
any effect whatsoever on operations e.g. on finals to runway 26 at Exeter International
Airport and between the military airfields at Merryfield and Yeovilton. In the US it is
becoming common to construct solar arrays within the airfield/airport boundary and this is
permitted within the UK subject to CAA approval.
It is possible that aircraft may experience momentary direct or indirect reflection from solar
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arrays. These occurrences are very transient and are dependent on a number of factors
including time of year, time of day, altitude, aircraft relationship to the array, etc. With that
said, the albedo (measure of reflectance) of the PV modules is lower than other common
surfaces in the surrounding area, including agricultural vegetation, windows on the nearby
industrial units etc. In addition, large-scale solar projects have been installed at or near
major airports around the world without incident or serious complaints from pilots .7
UK Experience
The UK has seen a recent surge in planning applications for large scale solar arrays and
many are in the vicinity of civil airports and military airfields or air routes; WFAC could not
find any instance where Planning Permission was refused based on anticipated glint and
glare issues. Examples of planning applications and assessments are varied in their nature
by virtue of roof or ground mounted and distance from runways but studies considered by
the respective Local Authorities into the glint and glare of developments at London City,
Newcastle and Coventry airports accepted that there would be no impact.8 In WFAC‘s opinion there are no implications with the meaning of the stipulations of the Air Navigation
Order.
Additionally the UK Ministry of Defence would appear to have accepted the results of such
assessments subject to design and installation considerations. At a recent Planning
application the MOD response stated:
“The proposed development relates to a large scale expansion of existing ground mounted solar
array at a site approximately 4.3km southeast of Merryfield Airfield. The potential for such a
large scale solar array to cause glint and glare is an aviation safety consideration. The design
and access statement supporting the application identifies that the panels are designed to absorb
sunlight and will produce no discernable (sic) glare or reflection. On this basis I can confirm
that the MOD has no safeguarding objections to this proposal.”’9
Manchester Boston Airport
Due to a singular experience in the USA (of a glare issue at Manchester Boston Airport) that
incidence is often quoted by pilots and airport operators as the example that validates their
concerns regarding visual impacts from solar arrays. In that case it is correct that twentyfive per cent of the array had to be decommissioned whilst a solution to a glare issue which
was described as a “distraction” by controllers was devised. The effect was apparent on one
7
FAA, Technical Guidance for Evaluating Selected Solar Technologies on Airports, FAA –ARP-TR-10-1. Page 41. Online at
http://www.faa.gov/airports/environmental/policy_guidance/media/airport_solar_guide_print.pdfhttp://www.faa.gov/airports/.../po
licy_guidance/.../airport_solar_guide_print.pdf
8 Example: Warwickshire County C ouncil’s Barrack Street Offices WDC/11CC021 20 December 2011
9 Area West Committee – 19th September 2012 Officer Report On Planning Application: 12/02823/FUL
15
of the line of panels within the total array and existed for about 45 minutes each morning;
this is in keeping with the findings of research which has concluded that glare is dependant
on the position of the sun, season and can be expected to be experienced from any fixed
viewing location for about 30 – 45 minutes per day.10 In the instance of Manchester Boston
the air traffic control tower was elevated above the array and the controllers were looking
down on it. The interim solution, whilst a permanent rectification is designed, was to cover
the offending panels; that permanent solution is considering altering the angle of the array
from the current 20o tilt, moving/removing some of the panels or putting blinds in the
control tower.11 The Manchester Boston ATC issue would appear the only experience of
such an event to date.
There were no complaints from pilots.
Glare Modelling in the vicinity of Scampton
In applying the FAA modelling tool to the proposed RAF Scampton array the following
parameters were applied:
all times are UTC + 0.00
a panel tilt of 20 degrees,
smooth glass with Anti-Reflective Coating,
defining the panels within the proposed boundary on an orientation of 180 degrees,
measuring from 2 miles finals to runway 03 at quarter mile intervals,
on a 3 degree glide path (319ft/mile)
threshold crossing at 50ft.
A pilot’s position of 2m above the specified threshold
eight additional points measured to represent level flight south of the array.
Only runway 04 is considered to have any potential for any visual impacts from the air; all
other runway are north of the planned array and, therefore, would be facing the back of the
panels.
The potential for glare during take-off is not considered within US risk assessments,
presumably as the aircraft is in a nose up configuration; in any event, there are no runways
at Scampton where aircraft departing would be flying towards the panels or even in the
general direction of the array.
For the purposes of this report the modelling conducted focusses on the specular reflection
of sunlight from solar panels discussing the persistence of an observer’s exposure to them 10
Panoche Valley Solar Farm Project Glint and Glare Study, POWER ENGINEERS May 21 2010
11 Manchester Union Leader newspaper, 30 August 2012 – interview with the Airport Deputy Manager (Mr Brian O’Neill) et al
16
where necessary. Specular reflections of sunlight are much more intense – hence significant
– than non-specular ones, so by focussing on the specular variety, the worst case is captured.
The solar farm has been modelled in two separate arrays as representative of the actual
development and with the assessment conducted across the internal area.
Figure 7 – the defined boundary points of the Burton array. Source SNLSGHAT
Sun position data for one year was predicted at 1 minute intervals and directions of solar
reflections calculated for each data point. For the purposes of the report the current year,
2014, was used for illustration. It must be noted that at any instant, solar reflections across
the whole solar farm will be parallel in a single discrete direction: the direction changing
slowly through the day and year.
17
Figure 8 – the defined boundary points together with elevations for PV Array1
18
Figure 9 – the defined boundary points together with elevations for PV Array2
When in shade, but otherwise illuminated by an entire blue sky, the typical ambient light
level is around 20,000 lux12; midday light levels with an overcast sky are typically 10,000 to
25,000 lux. For solar reflections to be seen from any surface, the sun must be shining so
ambient light levels will be high and the worst case effects caused by looking at or near
reflecting panels. These effects will never be as harsh as looking directly towards the sun or,
perhaps, when driving a car or landing an aircraft towards sunset both of which are
relatively commonplace events but neither of which are considered to be safety issues.
The lux is the SI unit of illuminance and luminous emittance, measuring luminous flux per unit
area.
12
19
For reflections from a solar array to be have any potential to become an issue, the panels
must be close to the direction of a viewer’s main interest for extended periods. There is considered to be no possibility of ‘flash blindness’ from brief exposure to solar reflections is
given the high ambient light levels that must be present for such effects to occur; brief
exposure to reflected sunlight from solar panels may be considered to be less significant
than prolonged exposure.
From the perspective from the control tower at the aerodrome the array will be facing away
from the ATC tower and arranged on a downward slope to the south; given the intervening
terrain and the natural topography of the site it is likely that the controllers will be
unsighted to most, if not all, of the panels. With the location of the tower to the north of the
development any line of sight will be to the reverse aspect of the solar array; there can be no
likelihood that the air traffic controllers will experience any glint or glare from the
development.
In the case of a solar farm viewed from an aircraft, such prolonged exposure can normally
only occur when a pilot is flying in a straight line in the general direction of the solar farm;
the most likely instance being where the solar farm is close to a runway and the aircraft is on
approach to the runway, descending to land.
Aircraft approaching to land at Scampton may meet these criteria with respect to the Burton
Farm solar array proposal only on approach to runway 04 13 . Aircraft commencing a
‘straight-in’ approach to land at long distances from the runway may, in theory, be subjected
to solar reflections for longer periods of time (due to the slow rate of change of bearing and
vertical angle from the solar farm).
For aircraft on approach to land at runway 04, the following points were modelled assuming
a 3 degree glide path from 2 miles finals i.e. 2 miles from the runway threshold, a maximum
downward viewing angle of 30 degrees and a threshold crossing height of 50ft.
Runways are referenced with numbers depending on the runway direction and with the runway
number being the approximate heading rounded to the nearest 10° and divided by 10.
13
20
Figure 10 – observation points on the approach Source: SNLSGHAT
Figure 11- observation points and heights on approach
21
A further range of observation points were assess representing a transit past the airfield
parallel to the runway, south-west/north-east and in proximity to the arrays (positions 1 –
50) and south of the airfield routing west to east (positions 1 – 8); all at 1000ft agl.
Figure 12 – solo observation points
Source: SNLSGHAT
Figure 13 – additional points assessed as representing level flight
22
Those results of the modelling are now considered in some detail:
Figure 14 – glare modelling results for Array 1
Figure 15 – glare modelling results for Array 2
23
The figures show that for both of the arrays, or for the array in total, there will be no glare
experienced on the final approach to runway 04 at Scampton inside 2 miles; glare would be
experienced at the observation points 5 and 6 and this is expanded on. For Array 1:
Figure 16 -Observation Point 5
The modelling results show that, at Observation Point 5, there is potential/low potential for
any temporary after image as a result of any glare from the array for approximately 40
minutes between the hours of 1700 and 1800 during the months of March/April and
August/September.
24
Figure 17 - Observation Point 6
The modelling results show that, at Observation Point 6, there is low potential for any
temporary after image as a result of any glare from the array for approximately 20 minutes
between the hours of 0600 and 0700 during the months of May/June/July.
25
For Array 2:
Figure 18 - Observation Point 5
The modelling results show that, at Observation Point 5, there is low potential for any
temporary after image as a result of any glare from the array for approximately 40 minutes
between the hours of 1700 and 1800 during the months of March/April and
August/September.
26
From the conclusions of the modelling it would appear that there is some limited potential
for glare from the solar development for aircraft flying in the vicinity of the solar array and
for brief periods very early in the morning and in the late afternoon; neither is considered
significant in terms of aviation in the area of the airfield. Furthermore, the proposed solar
arrays are within the Restricted Area surrounding Scampton and which is explained later.
From the perspective of flying at Scampton, and because of the nature of the military flying
that occurs there, it is necessary to consider the airfield specifically and in some further
detail.
RAF Scampton
The proposed solar development is approximately 4km south of Scampton.
RAF Scampton is the home of the Royal Air Force Display Team: The Red Arrows. The
Team practice their display routines at the airfield throughout the year.
Flying activity at the airfield is normally confined to the north west of the main 04/22
runway; accordingly, aircraft flying from/to/at Scampton will not normally be operating in
the area of the proposed solar park (See Figure 19). From the various parts of the airfield
and its visual circuit patterns, the solar park can be viewed in a south westerly direction
through to a south easterly direction.
The solar park is at a latitude of 53.15 north and, over the quadrant (SW-SE), the sun reaches
a maximum elevation of 60 degrees midday midsummer and 5 degrees midwinter just after
sunrise and just before sunset (sunrise and sunset occur just outside the SW-SE quadrant).
When assessing any potential sun reflection from the arrays, sun elevations between 5 and
60 degrees will need to be considered.
Scampton Visual Circuits
Figure 19 illustrates the extended centre-line and visual circuits flown at Scampton; it can be
seen that the flying activity is to the north west of the extended centre-line and the proposed
Burton Solar Park is to the south east of the centre-line.
27
RAF SCAMPTON
BURTON SOLAR PARK
Light Aircraft (Tutor/Tucano)
Visual Circuit
Fast Jet & Red Arrows
Visual Circuit
Extended Centreline – Departing
& Recovering
RAF Scampton – Visual Circuits
Figure 19 - Visual and Circuit Flying at Scampton in relation to the Burton Solar Park
The Red Arrows
Similar to other visual flying at Scampton, Red Arrows displays are flown to the north west
of the runway which is used as the crowd line.
It is acknowledged that the Syncro-Pair do cross the crowd line near the ends of the runway,
and the team arrivals are flown from behind the crowd line, both of these activities are
undertaken at low level/altitude.
The Red Arrows Restricted Area, EGR 313, is centred on the runway centre point, is 5nm
radius (9.2km) and extends to 9500ft above sea level (approximately 9200ft above the
runway). Whist EGR 313 protects the Red Arrows from other aircraft in the area, not all of
28
this area is used for display practice which will be concentrated in the red area shown in
Figure 20 below.
RAF SCAMPTON
BURTON SOLAR PARK
Red Arrows Practice Display
Area – representative only,
not necessarily to scale
Red Arrows – Practice Display Area
Figure 20 - Red Arrows Display Flying at Scampton in relation to the Burton Solar Park
Sunlight Reflection from the Solar Park at Scampton
Modern solar panels are constructed of materials that minimise the reflection of sunlight;
panels are designed with a layer of anti-reflective material that allows the sunlight to pass
through to the silicon but minimizes reflection and typically as little as 2% of the incoming
sunlight is reflected, assuming use of anti-reflective coatings. Moreover, the latest
generation of solar panels produce electricity from a much wider spectrum of light so
reflectivity is further reduced to maximise this ability. Notwithstanding this minimal
reflectivity, the reflection of sunlight will be analysed from the visual flying perspective.
29
As stated previously, at the latitude of Scampton/Burton Solar Park the sun elevation will
range from 60 degrees in midsummer to 5 degrees in mid-winter. The solar arrays proposed
for Burton are set at 20 degree tilt from the horizontal, facing south.
From Figure 21, it can be seen that the lowest elevation sunlight at 5 degrees what minimal
reflection that occurs will be reflected 45 degrees up towards Scampton; the maximum
elevation sunlight at 60 degrees will be reflected back south away from Scampton; and the
average sunlight at 30 degrees, will be reflected up at 70 degrees.
100 deg
70 deg
60 deg
30 deg
45 deg
No Reflected Light Below 45 degree
5 deg
20 degree tilt
Not To Scale – For Illustration Only
Figure 21: Sunlight Reflected by a 20 Degree Tilt Solar Panel
The view from most cockpits (including high-visibility fighter aircraft) is restricted in the
downward direction. Typically the pilot will be limited to around a maximum of 30 degrees
below the horizon unless the aircraft is manoeuvred (banked). As a result, reflected light
from 45 degrees below the horizon will not be visible from the cockpit especially if that light
originates as weak sunrise/sunset light. At the more typical reflection at 70 degrees, the light
will be well below that visible to the pilot. Nonetheless, the impact of a reflected sun light at
the minimum 45 degrees in the direction of Scampton will be assessed.
30
Reflected Sunlight Over RAF Scampton.
Taking the worst case reflected light, 45 degrees, and projecting that over RAF Scampton the
following results are evident (Illustrated in Figure 22):
At the airfield overhead datum the light will not be seen below 14,100ft (the Red
Arrows typically display up to 6000ft).
At the southern end of the runway the light will not be seen below 10,500ft.
On the southern finals turn to land (aircraft pointing at the solar park) the reflected
light will not be seen below 8850ft (aircraft in this position are below 1000ft).
On the extended centre-line, passing the Solar Park, the reflected light will not be
seen below 5250ft (aircraft landing will be below 800ft; aircraft taking off below
2000ft).
Note: If considering the average sun elevation (30 degrees), the reflected height figures
above can almost be trebled for the reflection at 70 degrees.
31
Figure 22 - Height of Reflected Sunlight over Scampton from the Burton Solar Park.
The construction of the Burton Solar Park 4km to the south of RAF Scampton will not affect
the operations at the Airfield either by its physical presence or by sunlight reflection. It is
clear that pilots will be able to see the Park during flying operations at Scampton (e.g. in the
visual circuit); however, the Park will quickly become part of the ‘known environment’ that exists around the airfield and it will not present a distraction to aircrews.
32
Glint and Glare Conclusions
Relying on the best experience of countries such as USA and Germany, and based on the
best advice and wide body of research available, there would appear to be little evidence to
suggest that the Burton Farm solar array development would have any significant impact on
the operations at RAF Scampton as a result of any visual effects.
The percentage of all sunlight reflected by modern solar panels is less than that reflected by
bare soil or vegetation and on a par to open water (lakes). Moreover, there have been no
formally reported incidences of solar panel glint & glare distraction to pilots in the UK.
The construction of the Burton Solar Park 4km to the south of RAF Scampton will not affect
the operations at the Airfield either by its physical presence or by sunlight reflection.
33
Overall Conclusions
There are no physical safeguarding implications resultant from the proposed development.
There is no basis in aviation safeguarding regulation or guidance for the refusal of the
application.
There is no evidence to support any statement that the solar farm will cause any visual
impact on pilots flying from or in the vicinity of RAF Scampton airfield.
In WFAC’s view there are no implications under the requirements of the UK Air Navigation
Order as a result of the proposed development.
Shane Savage B.Sc.
Managing Director
www.wfac-ltd.co.uk
34
Additional Sources:
Hazard Analysis of Glint and Glare from Concentrating Solar Power Plants, SolarPaces 2009,
Berlin Germany. Ph.D., Sandia National Laboratories, Clifford K., Cheryl M. Ghanbari, and
Richard B. Diver. 2009.
Potential Impacts from Reflection of Proposed Calipatria Solar Farm I & II Draft Date: March
24, 2011
SunPower. 2009. SunPower Solar Module Glare and Reflectance, Technical Report - *T09014.
SunPower Corporation, September 29, 2009.
The Airport Co-operative Research Program Synthesis 28 - A Synthesis of Airport Practice
Investigating Safety Impacts of Energy Technologies on Airports and Aviation.
Administration
35
Acronyms
Acronym
Full Description
AGL
Above Ground Level
AIAA
Area of Intense Aerial Activity
AIP
Aeronautical Information Publication
AMSL
Above Mean Sea Level
APPS
Approach Surface
ATC
Air Traffic Control
ATZ
Aerodrome Traffic Zone
CAA
Civil Aviation Authority
CAP
Civil Aviation Publication
CAS
Controlled Airspace
DME
Distance Measuring Equipment
DIO
Defence Infrastructure Organisation
DVOR
Doppler VHF Omni-Directional Range
GA
General Aviation
HMR
Helicopter Main Route
IAP
Instrument Approach Procedure
IFP
Instrument Flight Procedure
ILS
Instrument Landing System
IMC
Instrument Meteorological Conditions
LARS
Lower Airspace Radar Service
LFA
Low Flying Area
LPA
Local Planning Authority
LoS
Line of Sight
MAA
Military Aviation Authority
MATZ
Military Air Traffic Zones
MOD
Ministry of Defence
MSD
Minimum Separation Distance
NATS
National Air Traffic Services
NERL
NATS En Route Ltd
NM
Nautical Mile
NPPF
National Planning Policy Framework
36
Acronym
Full Description
OS
Ordnance Survey
PAR
Precision Approach Radar
PSR
Primary Surveillance Radar
RAF
Royal Air Force
RAP
Recognised Air Picture
RMS
Root Mean Square
RN
Royal Navy
SDSR
Strategic Defence and Security Review
SRTM
Shuttle Radar Topography Mission
SSR
Secondary Surveillance Radar
TMA
Terminal Manoeuvring Area
TOCS
Take-Off Climb Surface
UAV
Un-manned Air Vehicle
VFR
Visual Flight Rules
VHF
Very High Frequency
VOR
VHF Omni-directional range
37
Glossary of Terms
Air Traffic Service (ATS)
A generic term meaning variously, flight information service, alerting service, air traffic advisory
service, air traffic control service (area control service, approach control service or aerodrome control
service).
Aerodrome Traffic Zone (ATZ)
The airspace in the vicinity of an aerodrome, the size of which is dependent on the length of the
runway.
Directorate of Airspace Policy (DAP)
The airspace approval and regulatory authority that conducts the planning of airspace and related
arrangements in the UK. It ensures that the UK airspace is utilized in a safe and efficient manner
through the development, approvals and enforcement of policies for the effective allocation and use
of UK airspace and its supporting infrastructure taking into account the needs of all stakeholders.
Distance Measuring Equipment (DME)
A combination of ground and airborne equipment which gives a continuous slant range distancefrom-station readout by measuring time-lapse of a signal transmitted by the aircraft to the station and
responded back. DME can also provide groundspeed and time-to-station readouts by differentiation.
Deconfliction Service (DS)
A radar service whereby pilots will be passed the position of conflicting traffic, followed by advice to
maintain separation. Exceptionally, at controllers’ discretion, separation advice will be given first,
followed by the position of the conflicting traffic.
Final Approach Track (FAT)
Between 4 and 12 nms of straight flight descending at a set rate (usually an angle of between 2.5 and 6
degrees) following the magnetic track of the designated runway prior to landing.
Flight Level (FL)
A surface of constant atmospheric pressure, which is related to a specific pressure datum (1013.2mb,
also known as the standard pressure setting, or SPS) and is separated from other such surfaces by
specific pressure intervals. FLs roughly equate to thousands of feet, thus FL170 is around 17,000ft. All
aircraft above a certain altitude fly on the SPS, which then guarantees vertical separation between
aircraft.
General Aviation (GA)
All flights other than military and scheduled flights, both private and commercial.
Height
The vertical distance of a level, a point or object considered as a point measured from a specified
datum.
38
Instrument Flight Rules (IFR)
To be obeyed by pilots when it is not possible for an aircraft to be flown in Visual Meteorological
Conditions or at night, or when operating in airspace in which IFR must be adhered to in all
meteorological conditions.
Lower Airspace Radar Service (LARS)
A radar service given by certain radar equipped airfields to aircraft flying within the radar coverage
of that facility.
Reporting Points
Navigational points within a piece of CAS (normally part of an airway).
Traffic Service (TS)
This service provides only traffic information i.e. bearing, distance and if available the level of
conflicting traffic. No avoiding action will be offered and pilots are wholly responsible for
maintaining separation from other traffic whether or not controllers have passed traffic information.
Standard Arrival Route (STAR)
A designated IFR arrival route linking a significant point, normally on an ATS route, with a point
from which a published instrument approach procedure can be commenced.
Secondary Surveillance Radar (SSR)
SSR differs from PSR in that it transmits a coded interrogation as a series of pulses to a responder
fitted to the aircraft. When the transponder receives the message it responds with a coded reply, the
content of which is dependent on the type of interrogation. The coded reply can be one of several
parameters. The azimuth of the radar scanner at the time of the reply and the time delay between
interrogation and reply derive the azimuth and range of the aircraft relative to the radar. In addition,
the interrogation can be used to ascertain the barometric height of an aircraft. SSR is an active system
and only displays returns on a PPI from suitably equipped aircraft and thus is immune to the clutter
arising from passive reflective objects that affect PSR.
Special Visual Flight Rules (SVFR)
A flight made at any time in a control zone which is Class A airspace, or in any other control zone in
IMC or at night, in respect of which the appropriate air traffic control unit has given permission for
the flight to be made in accordance with special instructions given by that unit instead of in
accordance with the Instrument Flight Rules and in the course of which flight the aircraft complies
with any instructions given by that unit and remains clear of cloud and in sight of the surface.
Very High Frequency Omni-Directional (Radio) Range (VOR)
A radio navigation aid operating in the 108-118 MHz band. A VOR ground station transmits a 2phase directional signal through 360 degrees. The aircraft’s VOR receiver enables a pilot to identify his radial or bearing from/to the ground station.
Visual Flight Rules (VFR)
Meteorological conditions expressed in terms of visibility, horizontal and vertical distance equal to or
39
better than a specified minima.
Visual Reference Point (VRP)
A prominent natural or man-made feature which will be readily identifiable from the air established
in the vicinity of an aerodrome located within CAS in order to facilitate access to and from
aerodromes located within, and transit of, CAS by VFR traffic. They may also be used to assist pilots
to plan routes around CAS when traffic conditions require.
40
PROFESSIONAL QUALIFICATIONS AND EXPERIENCE
Cdr Shane Savage BSc, RN (Retd)
In over 28 years in the Royal Navy Shane had over 25 years’ experience in operational Air Traffic Control, (ATC), Fighter Control (FC) and Air Defence operations and Danger Areas Management.
Having been awarded Helicopter Pilots’ wings in 1986 he was employed at every level from
operational controller, through training management, operational management, up to national and
international policy and regulation as Head of ATC and FC and Danger Areas Regulation for the
Royal Navy. Shane is now the Managing Director of Wind Farm Aviation Consultants Ltd, a
consultancy set up specifically to advise the renewable energy industries on aviation issues. Since
2012 he has written aviation assessment reports on both solar and wind power developments on over
250 proposals for clients in the UK and has been engaged as an adviser by Local Authorities on the
implications of renewable energy developments on aviation.
Experience and Qualifications
2010 – 2011 – Head of Air Traffic Control, Fighter Control and Aviation Operations Support for the
Royal Navy
Responsible for Air Traffic Control, Aviation Operations Support and Fighter Control leadership,
policy, regulation and service delivery at 4 airfields, 1 Area Radar Unit, 3 Aircraft Carriers and all RN
operations throughout the world. Shane was responsible for the safe operation of all Naval Danger
Areas, Exercise Areas and Ranges and, until July 2011, the examination and staffing of all wind farm
issues both on and off shore. Additionally he was the Infrastructure Desk Officer for the Fleet Air
Arm and was the Head of Royal Naval aviation safeguarding.
2008 – 2010 Joint Air Land Organisation HQ Air Command (JALO) – Concepts and Doctrine for Air
Land Integration
Shane was the MOD lead for the development and assurance of Forward Air Controller Close Air
Support Tactics, Techniques and Procedures in addition to having lead responsibility for the
41
development of air battlespace management doctrine and instructional courses to enhance safety in
theatre and in training. As the UK representative to the US Joint Forces Command’s Joint Fires Organisation he was responsible for the UK input on Air Battlespace Management. Additionally, he
was UK representative to the US/NATO/Coalition Joint Close Air Support Executive Steering
Committee with respect to Secure Data Links in Airspace Management.
2006 – 2008 Ministry of Defence, Whitehall, Directorate of Joint Capability (Intelligence
Surveillance, Target Acquisition and Reconnaissance) with responsibility for Air Traffic Control
Policy and ATC Equipment Procurement)
Shane was the MOD Policy lead and Joint User for Project Marshall, the Joint Military Air Traffic
System. Further roles included being the MOD representative on the National IFF/SSR Committee
and Chair of the Defence IFF/SSR Steering Committee with MOD Lead responsibility for Mode “S” SSR policy and equipage for both ground interrogators and airborne platforms. Other responsibilities
included the MOD lead on the development of policy and regulation for Unmanned Air Systems
airspace including design and implementation of the D122 complex in southern England. Single
Service responsibilities included RN Policy lead for all aspects of MOD ATC and Airspace Policy in
the ‘Head Office’. This included MOD sponsorship of Joint Service Publication 552 (JSP 552), Military Air Traffic Service Regulations.
He was a member of the following regulatory and advisory bodies at varying times over the
period:
CAA National Air Traffic Management Advisory Committee
CAA/MOD National Flight Safety Committee
UK Air Prox Board
UK Air Safety Initiative Wind farms Working Group
CAA Danger Areas User Group
UK Airspace Strategy Steering Committee
MOD Airspace Requirements Review Team
National UK IFF and SSR Committee
Defence UK IFF and SSR Committee
42
MOD Wind farm Policy Group
Military Users Airspace Co-ordination Team
MOD Air Command and Control Programme Delivery Board
MOD ATC Aviation Safety Board
MOD Air Traffic Management Performance Criteria Working Group
MOD UAV Airspace Design Working Group
USA Joint Forces Command Executive Steering Committee on Air Battlespace Management,
Close Air Support and Digital Data links
MOD Mode S Working Group
MOD/NATS Joint Future Airspace Design Team
MOD/CAA Flexible Use of Airspace Policy Group
Royal Navy lead for all aspects of Project Marshall, the MOD ATC replacement radar
programme
2004 - 2006 Senior Air Traffic Controller (SATCO) RNAS Culdrose
At that time Culdrose was one of the busiest military mixed traffic airfields in Europe; Shane was
responsible for all aspects of aviation operations support, including air traffic control, safety, crash
fire and rescue, maintenance and service delivery. Culdrose was then the base for all Merlin, Seaking
ASW, Jetstream and Hawk fast jet operations. It was (and is) equipped with a Watchman radar,
Secondary Surveillance Radar (SSR), and a Precision Approach Radar (PAR).
2001 – 2004 Fleet Command Head Quarters – Staff Officer Air Traffic Control
As the “desk lead” for ATC and airspace management within the Fleet Headquarters Shane was
responsible for ensuring every aspect of Royal Navy ATC and associated support functions, both
ashore and afloat, and that these areas were able to deliver the necessary operational capability when
and where required. Primary responsibilities included determining and implementing Royal Navy
policy on Safety Management and Airfield and radar safeguarding. He was tasked with ensuring
that ATC Standards and Practices, ashore and afloat, met with appropriate military and national
procedures and safety regulations through continuous review of regulations and engagement with
43
other ATC service providers and with ensuring policy compliance through regular informal visits
and annual Formal Inspections to assure conformity of individual unit ATC service delivery. He
represented the RN on the UK AIRPROX Board, UK Alternative Energy Committee, Inter-Service
ATC Training, Safety Management and Airspace/ATC Policy Boards.
Prior to these last posts he had a varied history within airspace management within the full spectrum
of ATC, airspace management, airspace training and delivery and operational RN Executive Officer
employment including but not limited to:
1999 - 2001 – Senior Air Traffic Control Officer, Flag Officer Sea Training Plymouth Military
Radar.
44
Sqn Ldr Mike Hale MBE MSc CFS RAF (Retd)
Mike has over 40 years piloting, instructing and examining experience around most of the globe
ranging from numerous military fast jet aircraft including Lightning, Phantom and Tornado, through
a range of civilian and military GA craft. For the last, to 7 years he has also acted as Chairman of a
large military Gliding Club.
Mike’s flying experience to date includes 9000 total flying hours including:
Lightning 1979 – 1986
Phantom 1986 – 1989
Jet Provost 1989 – 1991
Tornado 1991 – 2002
Chipmunk, Bulldog, Tutor.
in addition to various Qualified Warfare Instructor (QWI), Qualified Flying Instructor (QFI) Test Pilot
( TP), qualifications. He is currently the Head of the Cranwell Gliding Club.
Over the last 8 years, in parallel to his flying duties he has held the post of MOD Air Staff Low Level
Airspace Manager & Wind-Farm Subject Matter Expert. In this position he managed the UK low level
airspace and assessed over 14,000 planning applications against low flying, weapons range, specialist
airspace and aerodrome safeguarding criteria.
Mike has also managed two Air Staff Wind farm Flight Trials for the MOD, CAA, RUK and Trinity
House.
Throughout his career he has been a member of the following committees and working groups:
DIO Wind Energy Working Group - Pilot Member
MOD Low Flying User Group - Chairman.
MOD Airspace Review Committee.
MOD Low Flying Safety Group
MOD Low Flying Policy - Dep Chair
AWR User Group - Dep Chair
MUACT - LF Member
CANP-PINS - Chairman
UK Air Prox Board - LF Advisor
45
BGA/GSA - Exec Committee
DTI/DEBERR/DECC Windfarm Working Groups & Airspace Allocation Committees
Government Aviation Steering Group - Military Flying/Low Level Member.
BHA ESC - Military Member.
RUK/MOD Round Table Low Flying Member
DAIEG & GEOSPATIAL Low Flying Member
In 2012 he was awarded an MBE for generating a proactive and mutually successful working
relationship between the Wind Power Industry and the MOD Low Flying Operators.
46

Wind Farm Aviation Consultants Ltd

Transcription

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