airport land use compatibility: tall towers & solar panels · airport land use compatibility:...
TRANSCRIPT
Airport Land Use Compatibility:Tall Towers & Solar Panels
2019 Minnesota Airports ConferenceWillmar, MN
Marcus Watson, Senior Airport Planner, TKDA
Rylan Juran C.M., Aviation Planner, MnDOT Office of Aeronautics
Session Objective(s)QUnderstand regulatory requirements pertaining to tall
towers and solar panels around airportsQUnderstand role and responsibilities of key stakeholders
during the compatibility review processQGain awareness of MnDOT Aeronautics resourcesQEmpower you to better evaluate development requests
around your airport to maintain safe airport operations
Tall Towers
Potential Aeronautical ImpactsQVisual Flight Rules ProceduresQInstrument Approach/Departure ProceduresQRadar/NAVAID InterferenceQATC tower line-of-sight visibility
FAA Regulatory RequirementsTitle 14 CFR Part 77: Safe, Efficient Use, and Preservation of the Navigable AirspaceSubpart B (Notice Requirements)QNotification required when:
QObject is more than 200’ AGL in height
QPenetrates a 100:1 slope to 20,000 feet from runways > 3,200’
QPenetrates a 50:1 slope to 10,000 feet from runways < 3,200’
QNotification standards do not equal obstruction standards
QOnline “Notice Criteria Tool”
FAA Regulatory RequirementsTitle 14 CFR Part 77: Safe, Efficient Use, and Preservation of the Navigable AirspaceSubpart B (Notice Requirements)QSubmit notice by filing FAA Form 7460-1, Notice of Proposed
Construction at least 45 days before construction startQFile online at: www.oeaaa.faa.govQSupplemental notice may be required (e.g. within 5 days of
structure reaches tallest heightSubpart C (Obstruction Standards)QPresumed hazard unless FAA aeronautical study concludes
it is not a hazard
FAA Regulatory RequirementsNotice Criteria Tool via OEAAA
FAA Regulatory RequirementsSubmit Airspace Cases via OEAAA
FAA Regulatory RequirementsTitle 14 CFR Part 77: Safe, Efficient Use, and Preservation of the Navigable AirspaceSubpart D (Aeronautical Studies)QFAA evaluates the effect of the proposed construction or
alteration on navigable airspaceQFAA will issue a determination
QDetermination of No Hazard to Air NavigationQDetermination of Hazard to Air Navigation
QDetermination is not a building permit, no legal effect aloneSubpart E (Discretionary Review)QOpportunity to petition for discretionary review
FAA Airspace Determinations
QDetermine if height of object exceeds standards
QIdentifies aeronautical hazards
QLighting/marking recommendation
QSupplementation notification requirements
QExpiration date(s)
Minnesota Regulatory RequirementsMinnesota Statute 360.81 – 360.91: Regulation of Structure HeightsQThe safety, welfare, and protection of persons and property in
the air and on the ground….be maintained in a reasonably unobstructed condition for safe flight of aircraft.
QThe location, height, and identification of structures are regulated
QAirport zoning ordinance regulations apply locallyQPermit required in unzoned areas from MnDOT Aeronautics
MnDOT Aeronautics PermitQPermit is required for tall, non-transmitting structure
outside the airport’s zoned territory if…QMore than 500’ AGLQMore than 200’ AGL within 3 miles of an airport an increasing by
100’ for each additional mile out to 6 miles and 500’ AGL, QPenetrates primary, horizontal, conical, approach or transitional
FAR Part 77 surface, orQ Increases instrument approach or airway altitude/visibility
minimums
QRequired itemsQDiagram, location, elevations, height, marking/lighting, FAA
airspace determination
Local Regulatory RequirementsQLocal Land Use Zoning RegulationsQAirport Zoning OrdinanceQFAA Grant Assurances
Roles & Responsibilities in Review ProcessQFAA
QDetermine effect of proposed construction on airspace
QMnDOT AeronauticsQReview permit for tall tower (as needed)
QAirport SponsorQProtect airspace (FAA Grant Assurance #20, #21)QRequest comments on FAA study (as needed)
QLocal GovernmentQAdminister airport zoning ordinance (as prescribed)QReview project proponent’s building permit/applicationQ Issue local building permit
QProject ProponentQFile notice to FAA (as required)
Development Scenario #1: Grain SiloQConstruct grain silo 75’ above
airport elevationQLocated 3,500 feet from runway
near but not within approachQNot an FAR Part 77 obstructionQAppears to be compliant with
airport zoning ordinanceQBuilding permit application
submittedQAirport manager hears about
proposal from neighbor QNo FAA airspace determination
Next steps in the development review
process?
Development Scenario #1: Grain SiloQAirport manager contacts local
zoning authorityQConfirms compatibility with airport
zoning ordinanceQFAA notification is requiredQLocal zoning authority requests
proponent submit notice to FAAQDetermination of No Hazard Issued,
FAA recommends obstruction lighting
QBuilding permit issued with obstruction lighting condition
Development Scenario #2: Cell TowerQConstruct cell phone tower 155’ above
airport elevationQLocated 9,200 feet from runway QFAR Part 77 obstruction to Horizontal
Surface (5 feet)QNot compliant with airport zoning
ordinance (airspace obstruction)QFAA Determination of No Hazard issued,
lighting recommendationQBuilding permit application submittedQNext steps in the development review
process?
Development Scenario #2: Cell TowerQPer Ordinance, Variance from Board of
Adjustment required before issuing building permitQFAA airspace determination
consideredQVariance requested and granted subject
to obstruction lighting installedQBuilding permit issued by local zoning
authorityQProject proponent submits FAA Form
7460-2 to notify FAA of maximum height
Development Scenario #3: Wind FarmQConstruct 10 wind turbines 580’
above airport elevationQLocated 5.1 miles from airportQFAR Part 77 obstruction QFAA 7460-1 submittedQIncreases instrument approach
minimums – impact to usersQBuilding permit application
submittedQNext steps in the development
review process?
Development Scenario #3: Wind FarmQFAA “circularizes” airspace case for
comments. Sponsor expresses concern.
QProponent agrees to lower wind turbine heights.
QFAA Determination of No HazardQProponent submits permit to
MnDOT Aeronautics for consideration. Approved.
QLocal building permit issued QProject proponent submits FAA
Form 7460-2 to notify FAA of maximum height
Recommendations for Airport SponsorsQUnderstand local airport zoning ordinance, and
responsibility for enforcementQEstablish relationship with local planning and zoning
authoritiesQRecognize Federal and State laws that apply to airspaceQVerify FAA notification and MnDOT permit requirements
are communicated to project proponentQDiscuss any concerns with project proponent – they usually
want to be good neighborsQContact MnDOT Aeronautics for assistance
Solar Panels
Rylan Juran, Aviation Planner
Rise of Solar
• 2007: 25% by 2025 green energy goal• Already close to half of MN energy comes from carbon
free sources• 2019: Gov. Walz plans carbon free MN by 2050• Xcel expects 85% carbon-free by 2030
Potential Aeronautical Impacts
https://share-ng.sandia.gov/glaretools/references/SGHAT_Ho.pdf
Glare viewed from control tower and Manchester/Boston Regional Airport
Glare
Conventional Wisdom
•Solar panels are designed to absorb light, not reflect it• Consider the source
• More true when sun is overhead
5/2/19 mndot.gov 25
https://www.forgesolar.com/help/
Conventional Wisdom
•I filed a 7460 and the FAA approved my project so I’m good.
5/2/19 mndot.gov 26
Regulatory Requirements
• Interim Policy, FAA Review of Solar Energy System Projects on Federally Obligated Airports• Effective 10/23/2013
• To obtain FAA approval to revise an airport layout plan to depict a solar installation and/or a ‘‘no objection’’ to a Notice of Proposed Construction Form 7460–1, the airport sponsor will be required to demonstrate that the proposed solar energy system meets the following standards:
• 1. No potential for glint or glare in the existing or planned Airport Traffic Control Tower (ATCT) cab, and
• 2. No potential for glare or ‘‘low potential for after-image’’ (shown in green in Figure 1) along the final approach path for any existing landing threshold or future landing thresholds (including any planned interim phases of the landing thresholds) as shown on the current FAA-approved Airport Layout Plan (ALP).
5/2/19 mndot.gov 27
Off-airport Installations
• Solar energy systems located on an airport that is not federally-obligated or located outside the property of a federally-obligated airport are not subject to this policy.
• Proponents of solar energy systems located off-airport property or on non-federally-obligated airports are strongly encouraged to consider the requirements of this policy when siting such systems.
5/2/19 mndot.gov 28
Conventional Wisdom
5/2/19 mndot.gov 29
•I filed a 7460 and the FAA approved my project so I’m good.
Hazard Plot
5/2/19 mndot.gov 30
• No glare in ATCT cab
• No yellow glare along 2 mile flight path
Case Study
5/2/19 mndot.gov 31
Dodge Center• Asked by County to
evaluate energy company glare study
• Especially concerned about traffic on HWY 56
• Provided study has 0 minutes of glare
Aviation Impacts
5/2/19 mndot.gov 32
HWY 56 Predicted Glare
5/2/19 mndot.gov 33
HWY 56 Hazard Plot
5/2/19 mndot.gov 34
Real Life Example
5/2/19 mndot.gov 35
• University Ave, St. Paul
• March 29, 8:00 • Uncomfortable
glare from building
Route with Vertical Surface
5/2/19 mndot.gov 36
5/2/19 mndot.gov 37
What Can I Do?
• MN Rules 8800.2400 Subpart 6.
• A. No use shall be made of any land in any of the safety zones which creates or causes interference with the operation of radio or electronic facilities on the airport or with radio or electronic communications between the airport and aircraft, makes it difficult for pilots to distinguish between airport lights and other lights, results in glare in the eyes of pilots using the airport, impairs visibility in the vicinity of the airport, or otherwise endangers the landing, taking off, or maneuvering of aircraft.
• Zone C restrictions since at least 70’s
5/2/19 mndot.gov 38
5 Takeaways
• Ensure your airport zoning is up to date• And enforced!
• Communicate glare issue to county• Many updating renewable energy ordinances
• Energy companies typically won’t model runway extensions or future crosswinds• Sometimes don’t know what they are doing at all
• FAA determination of no hazard is meaningless (re: glare)• Call Rylan early
• Location (drawing or Google Earth)• Panel orientation and tilt• Tracking or not• Height of panels• Total energy output
5/2/19 mndot.gov 39
Questions?
Marcus WatsonSenior Airport Planner
Rylan Juran, C.M.Aviation Planner