Aviation

Safety Aspects of a Wind Turbine

RJC
Looking towards Needwood Forest Gliding site from the proposed turbine

Near Hamstall Ridware, Staffs

Compiled by: R J Commander Commander Aviation Services For: J and S Bostock 13 February 2012 Amended: 19 March 2012 +44 (0) 1342 718879 +44 (0) 7767 834780

Dated:

info@commanderaviationservices.com www.commanderaviationservices.com J and S Bostock

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Notes on the Document

Copyright This document is copyright Commander Aviation Services Ltd CAS February 2012 Some photographs have been used which appear on Google Panoramio. As these photographs are already in the public domain, they are reproduced here. If there are subsequent objections to their use, they will be removed. The document may be reproduced as a whole for the purposes of the planning application as referred to in the content. In this context, the document must not be altered in any way without the permission of CAS. It is preferred that the document is reproduced in PDF format. Extracts may be made from the document but an acknowledgement of the source material should be included with any further reproduction. Use of the Document This document is intended to be read on a computer as a Word document. It is produced in DOCX format, which can be converted for earlier versions of Word. The hyperlinks to other web sites work in DOCX. The Word Document also has a clickable Table of Contents. The Word format is less stable for transmission than PDF and this may result in the corruption of some diagrams particularly when printing, so the Document is also presented in PDF format. Hyperlinks may not work in PDF format, but the Document is generally easier to read and should reproduce accurately electronically and as hard copy.

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Table of Contents

Notes on the Document ................................................................................................................................................................................................................................................................. 2 Copyright ................................................................................................................................................................................................................................................................................................. 2 Use of the Document ........................................................................................................................................................................................................................................................................... 2

Table of Contents ........................................................................................................................................................................................... 3 Aviation Safety Aspects of a Wind Turbine near Hamstall Ridware, Staffs ....................................................................................................... 4 Introduction ....................................................................................................................................................................................................................................................................................... 4 About the Author and CAS ........................................................................................................................................................................................................................................................... 4 Oversight of Aviation ...................................................................................................................................................................................................................................................................... 5 Legal Definitions ............................................................................................................................................................................................................................................................................... 5 Structures ................................................................................................................................................................................................................................................................................................ 6 Aerodrome Definition ......................................................................................................................................................................................................................................................................... 7 Gliding Sites and Farm Strips in the UK ................................................................................................................................................................................................................................. 7 Safeguarding of Aerodromes ...................................................................................................................................................................................................................................................... 9 En Route Obstacles in the UK .................................................................................................................................................................................................................................................. 10 Lighting on the Turbine ............................................................................................................................................................................................................................................................. 11 Visual Flight Rules (VFR) ........................................................................................................................................................................................................................................................... 12 See and Avoid ................................................................................................................................................................................................................................................................................. 12 Glider Operations in the UK .......................................................................................................................................................................... 14 The British Gliding Association .............................................................................................................................................................................................................................................. 14 A Typical Glider Circuit .............................................................................................................................................................................................................................................................. 16 Aviation Operational Risk Analysis: Wind Turbine at Hamstell Ridware, Staffs. ............................................................................................ 19 Introduction .................................................................................................................................................................................................................................................................................... 19 Method of Risk Assessment ...................................................................................................................................................................................................................................................... 20 The CAS Assessment for a Wind Turbine at Hamstell Ridware, Staffs ............................................................................................................ 22 Expanded Notes from the Table ............................................................................................................................................................................................................................................. 26 Conclusion ........................................................................................................................................................................................................................................................................................ 30 CAA Advice ....................................................................................................................................................................................................................................................................................... 31
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Aviation Safety Aspects of a Wind Turbine near Hamstall Ridware, Staffs

Introduction
An application for planning permission for the erection of a 75m high wind turbine on land near Hamstall Ridware, Staffs, resulted in objections on aviation safety grounds from the Needwood Forest Gliding Club which operates at Cross Hayes to the North of the proposed turbine site. In response to the objections, Lichfield Council proposed that the applicants under Planning Application 11/00449/FUL commission a risk assessment to quantify the likely risks to aviation generally and specifically to the local glider site should the construction of a single wind turbine be approved. The applicants have commissioned Commander Aviation Services (CAS) to carry out the risk assessment on their behalf and this document presents the completed risk assessment and also an introductory overview of recreational aviation and the rights of operation for a flying club in comparison to the surrounding farms and associated lands. The author had no previous connection with any of the interested parties in this planning application, and will comment primarily on the legal position with regard to light aircraft (including gliders, aeroplanes and helicopters), airstrips and gliding sites in the UK. CAS Ltd also has neither connection nor vested interest in general aviation or Government interests promoting alternative energy infrastructure.

About the Author and CAS

Bob Commander of CAS has prepared this risk assessment and regulatory overview. CAS specialises in aerial work and corporate aviation operations and advises The Crown Estate on aviation matters related to offshore renewables development. Bob Commander has considerable experience of General Aviation over twenty years, acting as Head of Policy for the Civil Aviation Authority from 1995 to 2006. A full CV is available on the CAS website under About CAS.

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Oversight of Aviation
Aviation in the UK is largely controlled by the rules set out as articles in the Air Navigation Order 2005 and as rules in the Rules of the Air Regulations 2007. The Order and the Rules are secondary legislation made under the law of the primary legislation, the Civil Aviation Act which was amended in 2006. The original Act of 1982 established the Civil Aviation Authority in this country and the CAA remains responsible for all aspects of UK aviation, from international airliners at Heathrow down to homebuilt microlight aeroplanes flying out of a farmers field, or in the case of a helicopter, a back garden.

Legal Definitions

The degree of freedom enjoyed by the owners of light aircraft 1and airfields in the UK may seem surprising in these days of micro-regulation. With the exception of the protected airspace around major airports, a pilot can take off from, and land, in any suitable field subject to the Rules of the Air which, inter alia, impose a 500 foot avoid area around persons, vessels, vehicles and structures. This is a dome-shaped area around and over the object or person to be avoided. This means that an aircraft can legally fly just above the surface in the UK provided it stays 500 feet away horizontally, vertically or anywhere in between - from the aforementioned persons, etc. Many other countries have a minimum height of 500 feet above ground level, with the exception of when taking off or landing. Rule 5 is the relevant rule and is commonly referred to as the Low Flying Rule. Reference to this Rule will recur and the critical part of the Rule is shown in the box on the next page for easy reference.

1 An aircraft is any flying device, including planes, microlights, gliders and balloons.

An aeroplane typically has wings and one or more engines.

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Rule 5 Extract
Except with the written permission of the CAA, an aircraft shall not be flown closer than 500 feet to any person, vessel, vehicle or structure. Exemptions from the low flying prohibitions
6 The exemptions from the low flying prohibitions are as follows: (a) Landing and taking off (i) Any aircraft shall be exempt from the low flying prohibitions in so far as it is flying in accordance with normal aviation practice for the purpose of: (aa) taking off from, landing at or practising approaches to landing at; or (bb) checking navigational aids or procedures at a Government or licensed aerodrome.

A glider cannot fly multiple practice circuits like fixed wing aeroplanes and therefore, in the vicinity of the glider site, on most occasions, it is either taking off or landing in accordance with normal aviation practice. This means that it should be at the normal heights associated with a glider circuit as shown on Page 16. Structures The Order does not define a structure. However, by legal precedent, this has become accepted by the CAA as meaning something capable of containing a person. Therefore for aviation purposes, a turbine is probably not a structure, while pylons and towers, including wind turbines capable of containing or supporting a person probably are. Probably is used here, as a court would have to decide on any particular case and rule accordingly. The proposed wind turbine is 75 metres (245ft) tall with access to the interior. Therefore, it is likely that the 500ft avoid distance imposed by the Low Flying Rule would apply in this case for passing aircraft which are not taking off or landing at Needwood. J and S Bostock Page 6 of 31 RJC

Legal Definitions (Contd.)

Aerodrome Definition

ANO Article 155 Interpretation 'Aerodrome' means any area of land or water designed, equipped, set apart or commonly used for affording facilities for the landing and departure of aircraft and includes any area or space, whether on the ground, on the roof of a b uilding or elsewhere, which is designed, equipped or set apart for affording facilities for the landing and departure of aircraft capable of descending or climbing vertically, but shall not include any area the use of which for affording facilities for the landing and departure of aircraft has been abandoned and has not been resumed.

Gliding Sites and Farm Strips in the UK

As can be seen from the ANO definition of an aerodrome, any reasonably flat farm field has the potential to be used for take off or landing in an aircraft (the term aircraft includes gliders; aeroplanes are powered). There are literally hundreds of farm strips in the UK, many being dedicated to microlight aircraft which in general have a shorter take-off distance requirement than a conventional light aircraft. The use of the land is only described as an aerodrome under the ANO definition. In planning terms, farm strips are usually used on the basis of not more than 28 days for that purpose in any year. For this, planning permission is generally not required provided there is no associated development. Interestingly, there is also no limit on the number of take-offs or landings that can be made on any day within the 28 days, whereas a more permanent airfield with associated planning permission is likely to have a limit imposed on the number of aircraft movements in a specified period and with opening and closing times also specified. In practice, the CAA is most unlikely to check compliance with the 28-day planning rule, but it is known from experience that neighbours often keep comprehensive records of the use of land adjacent to their own property.

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Most gliding sites in the UK are more similar to established airfields than farm strips while still coming within the ANO definition of an aerodrome. Most gliding sites are long-standing grass fields with planning permission for the specific use. Most are also marked on aviation low flying charts and those with a winch launch are marked as a hazard to other airspace users up to 2000ft+ above the surface. It is understood that the Needwood Forest gliding site has planning permission which imposes restrictions on the number of days use and periods of opening and also the number of movements per day. The Club website also suggests that operations open to the public for trial lessons are mainly restricted to weekends with Wednesdays added during the summer months. Week- long activity is only associated with occasional special club weeks. Although it is not included in the risk assessment per se, it should be noted that the level of activity at Needwood Forest is modest in comparison with clubs such as Lasham or the Scottish Gliding Club at Port Moak. For comparison, Lasham boasts over 220 gliders 2 based there, while Needwood has a base of 5 supplemented by members own aircraft. The objection from Needwood included figures of 4500 aircraft movements a year. An aircraft movement is counted when taking off, landing or making an approach to land without actually stopping, so this figure can be at least halved for each glider flight. A very rough calculation suggests that the Club could operate for about 80 days of the year, but weather (including grass field conditions) probably precludes a significant percentage of these with whole weekends being unflyable. Being conservative, this means that the Club actually makes an average of 2200 flights spread over about 50 days some 44 flights a day averaging about 5 approaches an hour.

2 Many are kept on site year round in trailers this is not apparent at Needwood on Google Earth.

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Safeguarding of Aerodromes
Civil Aviation Publication (CAP) 738 explains the process of safeguarding the airspace around an aerodrome. Safeguarding is a legal requirement around licensed aerodromes and is intended to ensure that development around the aerodrome does not encroach on the airspace needed to safely operate an aircraft. The CAP recommends that safeguarding should apply to all aerodromes, and as already explained, this could mean any mown grass strip in a field. However, CAP 738 is guidance material and the CAA does not monitor or insist on planning compliance for unlicensed airfields. Safeguarding is an agreed requirement under international convention, specifically the Chicago Convention and the subsequent Standards and Recommended Practices (SARPS) developed by the International Civil Aviation Organisation (ICAO). It is primarily intended to ensure that an international airliner is afforded the same standards of protection irrespective of where in the world it is taking off or landing (ICAO membership includes nearly all contracting states of the world). In practice, it is doubtful that this is achieved for all major airports throughout the world until relatively recently, Hong Kong Kai Tak airport was encroached upon by high rise buildings and it is still a continuing problem at Heathrow as London develops ever taller buildings. At smaller licensed aerodromes, the problem is even more acute. Many UK aerodromes have developments at both ends of the runway which were not there when the aerodrome was first licensed. Even for some quite major airports, full safeguarding is not achievable. For licensed aerodromes there is in fact a reducing scale of protection required depending on the status (size and usage in the main) of the aerodrome. Hopefully it can be seen therefore, that safeguarding is generally regarded as a good thing and is recommended as a starting point before laying out any landing strip. It must be stressed, however, that this is advisory and is not supported by the law. It should be noted that there is a tendency to cherry-pick safeguarding standards to suit the operator. Many airstrips exist next to high-tension power lines and there are existing power lines with tall pylons in the vicinity of the Needwood site at a similar distance out and directly across the approach to the main runway direction of 280.
Pedrocut Panoramio

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En Route Obstacles in the UK

Notification of en route obstacles in the UK is organised by the Aeronautical Information Service (AIS) of National Air Traffic Services (NATS). Notification of temporary hazards is effected by issuing NOTAMS (Notices to Airmen). This is done largely by website these days. It is the pilots responsibility to ensure that a flight can be safely undertaken and, as part of pre-flight briefing, NOTAMS are checked for the route. NOTAMS only record temporary hazards and the proposed turbine will be a temporary structure and therefore notified. Permanent hazards with vertical extent are listed separately in the Aeronautical Information Publication (AIP, sometimes called the Air Pilot) En Route Section (ENR). Importantly the AIP ENR only lists obstacles which are over 300ft high (above the surface). There is no actual requirement therefore to notify the proposed turbine, either by NOTAM3 during construction, or for it to be listed as a permanent obstruction to en route navigation.

3 Notices to Airmen checked before flight by pilots for their flying route or area.

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An extract from CAP 764 - CAA Policy and Guidelines on Wind Turbines
5.3 Article 133 [now Article 219] requires that structures away from the immediate vicinity of an [licensed] aerodrome, which have a height of 150m or more (Above Ground Level) are fitted with medium intensity steady red lights, positioned as close as possible to the top of the obstacle, and also at intermediate levels spaced so far as practicable equally between the top lights and ground level with an interval not exceeding 52m. Obstruction lights should be illuminated at night, visible in all directions and, in the event of any lighting failure, rectified as soon as is reasonably practicable. 5.4 In addition, the CAA will provide advice and recommendations regarding any extra lighting requirements for aviation obstruction purposes where, owing to the nature or location of the structure, it presents a significant hazard to air navigation. However, in general terms, structures less than 150m high, which are outside the immediate vicinity of an aerodrome, are not routinely lit; unless the by virtue of its nature or location argument holds fast. UK AIP ENR 1.1.5.4 refers.

Lighting on the Turbine

The above extract from CAP4 764 applies to all obstructions but is explained clearly in this particular publication. Note that there is no requirement to light the proposed turbine (or any other turbine or structure of less than 150m high) in aviation regulation terms. CAP 764 is also misleading because the article refers to licensed aerodromes only. Needwood is not a licensed aerodrome, so this is an en-route obstacle by aviation definition. The type of lighting referred to is primarily intended for night use. Gliders fly during daylight hours only. There is no legal requirement for daytime hazard lighting such as the high intensity strobe more commonly associated with tall buildings such as Canary Wharf.

4 Civil Aviation Publication

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Visual Flight Rules (VFR)

Much of the general aviation flying in the UK is conducted under Visual Flight Rules and the weather minima for VFR are given in the box. Most light aircraft including gliders operate at less than 140 knots (c.160mph) and can therefore fly with a visibility of 1500m. A pilot may be limited to a higher visibility imposed by a condition on his flying licence. This is of course subjective on most occasions (Air Traffic can give an indication of visibility at an aerodrome using known landmarks), but this can be very different in an aircraft looking into sun or just a short distance away from the field. Before flying however, the pilot must get an up to date weather forecast which gives the expected visibility for an area which should be at least 1500m and hopefully better.

Rule 28 of the Rules of the Air Regulations

Weather minima for VFR flight outside Controlled Airspace .for an aircraft, other than a helicopter, operating at 140kt or less: 1500 m flight visibility, clear of cloud and with the surface in sight.

See and Avoid

An unmarked wind turbine such as is proposed would be difficult to see in 1500m visibility, as are power cables and other aircraft particularly fast moving military jets. As well as the VFR requirements, visual flying in the UK relies almost entirely on the principle of see and avoid. This applies to avoiding other aircraft in the main and the Rules of the Air state how to avoid another aircraft once it is seen; i.e. the direction to turn. However, not unreasonably, the pilot also has to avoid other obstacles on a see and avoid basis. As already explained, by no means are all obstacles plotted on maps or included in NOTAMS or other warning material. One of the most important things for a pilot is to develop knowledge of the local area. In this instance, once the turbine has been brought to the attention of the pilots it is up to them to make sure they avoid it. Additionally, the operator of an airstrip or glider site is required to notify other would-be users of any hazards in the local area. Other users should not land at an airstrip without first seeking prior permission and being briefed on any local hazards or unusual conditions. J and S Bostock Page 12 of 31 RJC

 The proposed turbine is very unlikely to be a significant hazard to en route traffic. The CAA advice to private pilots is that, wherever possible, they should transit above 2000ft to reduce noise complaints and, more importantly, to reduce the risk of confliction with low flying military training. There is also minimal risk to these military aircraft, which stay between 500ft, and 1000ft above ground level (agl) except in areas of the country associated with very low flying training where they can be cleared down to 250ft agl. In fact, the gliding site at Needwood is a much greater hazard to transiting aircraft because, although its location is marked on the map, it launches its glider using a winch cable which tows the glider to a height of between 1400 and 1600 feet agl. As can be seen from the picture, the cable is very difficult to see and extends to about five times the height of the proposed wind turbine.

Schapmande13 Panoramio

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Glider Operations in the UK

The British Gliding Association

While the CAA has overall responsibility for all flying activities in the UK with the ultimate responsibility resting with the Department for Transport, glider operations to a very large extent are looked after by the British Gliding Association (BGA) on a self-policing basis. To date this has included such matters as pilot training and qualification criteria, airworthiness for the gliders and a major input to the Air Accident Investigation Branch in the event of a glider accident. This long-standing arrangement is now being reviewed by the European Aviation Safety Agency (EASA), with the likelihood of more direct input from Europe on first licensing and then operational policy matters for UK gliding. This sea change means that the BGA is very protective of its established position (as it always has been) and resists change, rather than embracing it. This position is also true of the development of renewable energy resources and the need for wind turbines at many sites throughout the country. The initial reaction is to object on principle. That said, the BGA has done work on safeguarding gliding sites and this is evident on its website under Aerodrome Safeguarding. The picture on the next page shows a BGA specimen safeguarding map superimposed on Google Earth at the same scale. The author has added the measurements using Google Earth Ruler. The safeguarding is logically weighted toward take off and landing with a 2000m area where consultation is expected for any development higher than 10m. The area where consultation is required is reduced in the downwind or rejoining area to approximately 1600m abeam the runway. Importantly, there is no consultation required to the North or East of the field, but this is mainly influenced by the villages in this sector. Parham is home to the Southdown Gliding Club, which is active year round and has more than forty members gliders on site. The club also launches gliders by aerotow as well as by winch, so the circuit has to cater for fixed wing towing aircraft as well as gliders.

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A Typical Glider Circuit

The diagram below shows a typical glider circuit based on Needwood. As explained later on Page 26, this is simply an example to show general principles and in particular the actual shape of the circuit can vary widely from this. This diagram shows the options to recover to either end of the grass airstrip, but the diagram on the next page concentrates on recovering to Rwy 10, the orange circuit, where the aircraft is descending as it passes the proposed turbine (although remaining well above). On recovery for Rwy 28, the aircraft passes the turbine at circuit height commencing at about 700 feet above the surface.

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A detailed overview of glider operations is given later on Page 26 as a note to the Risk Assessment. The brief explanation here is intended as background information to those unfamiliar with flying in general and the sometimes-confusing terms that are used. The first oddity is that aviation mixes units of measurements5. Altitude is measured in feet either above the surface or above sea level and a pilot can set either of these as a datum on his altimeter. Height of an object on the ground is measured in metres. Horizontal distance is measured in metres, kilometres and Nautical Miles.

Secondly, the runway on an airfield is usually referred to as a compass bearing for the direction of take-off or landing. In the Needwood example shown below, the orange arrow indicates a downwind leg to land on Runway 100 (Abbreviated to Rwy 10). The downwind leg is typically started at 700 feet above the surface and usually up to 1000m out from the runway. Tighter (i.e. closer to the runway) circuits are flown by gliders with poorer performance and a 1000m is wide even for a modern high performance machine. The diagram shows a landing on Rwy 10 and this is reversed for a landing on the reciprocal, Rwy 28 (the same piece of grass, but the opposite direction). The prevailing wind in the UK is from the West, so most landings will be made into wind on Runway 28. The significant difference between the runways is that the glider approaching to land on the more usual Runway 28 will be at the start of its downwind leg and therefore 150 feet higher as it passes the turbine than it will be on the less frequently used Rwy 10.
5 The units are laid down by the International Civil Aviation Organisation, in Annex 5 to the Chicago Convention.

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The oblique view shows the turn crosswind and the final turn for landing. In both this view and the previous one, the actual turns are stylised and the pilot can select a variety of patterns as he approaches the end of the downwind leg usually turning in earlier to keep the airfield in sight (dotted line). During the downwind leg, the aircraft has descended to about 600 feet above the surface. As can be seen, the aircraft is about 500m clear of the proposed wind turbine horizontally and, as already discussed, it is nearly 300 feet higher than the highest extremity of the turbine blades. It is possible for an aircraft to join the circuit from the southwest and this could be flown over the turbine, as the aircraft would be joining at circuit height 1500m out from the airfield. In practice, most pilots would prefer to keep the turbine in sight, either to the left or right, as the aircraft passes. As explained on Page 12, gliders fly under Visual Flight Rules and therefore with a minimum visibility of 1500m. The proposed turbine will actually provide a useful feature to locate the airfield in relatively poor visibility (admittedly an unusual occurrence in gliding poor visibility is usually associated with a lack of lift). There is already a glider site with a wind turbine of similar proportion in a very similar position to the downwind circuit, but to the opposite runway, at Nympsfield in Gloucestershire (See Right). The Nympsfield turbine was erected in 1996, and after original objections from the local Bristol and Gloucester Gliding Club (BGGC), is now generally agreed to be part of the local (very picturesque) landscape, which does not affect gliding adversely. The BBGC has eight club gliders, two aerotow aircraft, and is open seven days a week. J and S Bostock Page 18 of 31 RJC

Aviation Operational Risk Analysis:

Wind Turbine at Hamstell Ridware, Staffs.

Introduction
This part tabulates a series of possible events which might occur due to a 75m tall wind turbine being erected near Hamstell Ridware and specifically looks at the increased risk this poses for gliding at Needham Forest gliding site. Assessments are only given for operational aviation related risks. A separate failure modes and effects analysis should consider technical failures and their minimisation by design. The Section starts with an explanation of the method used to assess the risks.

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Method of Risk Assessment

The failures or events have been assessed on the basis of Severity and Likelihood as described in the ICAO Safety Management Manual (ICAO SMM). A copy of the SMM is included in the PDF Portfolio with this document. Severity of Consequences Aviation Definition Catastrophic Meaning Equipment destroyed. Multiple deaths. Hazardous A large reduction in safety margins. Serious injury or death to a number of people. Major equipment damage Major A significant reduction in safety margins. Serious incident. Injury to persons. Minor Nuisance. Operating limitations. Use of emergency procedures. Minor incident. Negligible Little consequence. 1 Extremely improbable Almost inconceivable that the event will occur 1 2 Improbable Very unlikely to occur 2 3 Remote Unlikely, but possible to occur 3 4 Occasional Likely to occur sometimes 4 Value 5 Qualitative definition Frequent Likelihood of Occurrence Meaning Likely to occur many times Value 5

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 Severity against Probability Matrix

Extremely improbable 1 Severity Catastrophic 5 Hazardous 4 Major 3 Minor 2 Review 5 Review 4 Acceptable 3 Acceptable 2 Negligible 1 Acceptable 1 Multiplying Severity x Likelihood produces the matrix above. Red areas contain an unacceptable level of risk while Green areas are acceptable. Between the two is an area where the risk is significant but is acceptable, usually with mitigation. If there is no mitigation, the risks are deemed acceptable, but should be reviewed in the light of experience or changing technology or circumstances on a regular basis (annually?) to try to reduce the risk when and if possible. J and S Bostock Page 21 of 31 RJC Acceptable 2 Acceptable 3 Acceptable 4 Acceptable 5 Improbable 2 Unacceptable 10 Review 8 Review 6 Acceptable 4 Likelihood of Occurrence Remote 3 Unacceptable 15 Unacceptable 12 Review 9 Acceptable 6 Occasional 4 Unacceptable 20 Unacceptable 16 Review 12 Acceptable 8 Frequent 5 Unacceptable 25 Unacceptable 20 Review 15 Review 10

The CAS Assessment for a Wind Turbine at Hamstell Ridware, Staffs

Item 1 Event Air traffic into Needwood hits turbine: Straight in approaches to either Runway: (Rwy10 or Rwy28) Circuit approach to Rwy28 Circuit approach to Rwy 10 Severity x Likelihood 3x1 3x2 3x3 Total 3 6 9 Consequence Glider destroyed or serious damage. Serious injury or death Considerations Risk is on a par with normal flying See Discussion 1 under 3 below. This is not the predominant runway direction Mitigation Result / Final Total 3x1 3

None required 1. NOTAM of structure during erection. 2. NFGC warning to visitors of the temporary structure. 3. NFGC local procedures to ensure the risk of contact with the turbine is minimised. (e.g. Review local procedures. Add minimum height downwind until past the wind turbine. 4. NFGC pilot education programme RJC

3x2 6 3x2 6

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 Item 2 Event Gliders soaring or en route Severity x Likelihood 3x2 Total 6 Consequence Aircraft destroyed or serious damage. Serious injury or death Considerations See Discussion 2 under 3 below. Mitigation Same as 1 and 2 above. 3. En-route traffic has to avoid structures by 500ft. Pre-flight planning includes a check of NOTAMs for temporary en-route obstructions. Result / Final Total 3x1 3

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 Item 3 Event Transiting light aircraft traffic contacts turbine. Severity x Likelihood 4x2 Total 8 Consequence Aircraft destroyed or serious damage. Serious injury or death. Considerations Mitigation Result / Final Total 3x1 3

See Discussion 3. Same as 1 and 2 above. 3. En-route traffic has to avoid structures by 500ft. Pre-flight planning includes a check of NOTAMs for temporary en-route obstructions. 4. Avoidance of the turbine should ensure avoidance of the turbine. 5. Aircraft advised to transit above 2000ft in UK. 6. Needwood gliding site is marked as a 2km hazard circle on the CAAs flying charts and should be avoided by transiting aircraft. The proposed turbine will be inside this notified area.

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 Item 4 Event Military Low Flying Severity x Likelihood 3x2 Total 6 Consequence Aircraft destroyed or serious damage. Serious injury or death Considerations See Discussion 4 under 3 below. Mitigation 1. All as above for transiting light aircraft. 2. Military aircraft transit above 500ft even when low flying except in designated areas where they are cleared down to 250ft. 3. The 2km circle is marked on military flying maps. 4. The turbine will be marked on military low flying charts (obstacles over 150 ft. above the surface are all marked). Result / Final Total 3x1 3

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Expanded Notes from the Table

Item 1. Circuit traffic into Needwood hits turbine. This note should be read with reference to the diagram on Page 25. A current fixed-wing flying instructor and glider pilot provided these opinions, including the map. The pilot has over a thousand hours gliding, including about 10,000 landings, most of these as a glider instructor. However, this has not included landing at Needwood or Cross Hayes as it was previously called. The gliding club site (as per the Needwood Forest web site) is oriented WNW/ESE. Tatenhill aerodrome is a licensed aerodrome for aeroplanes, and is situated to the Northwest of the site. The glider movements should normally remain outside the Air Traffic Zone (shown shaded on the map), and therefore all circuits at the gliding club should be to the South of their field, which means that the turbine would be adjacent to the glider circuit pattern. Notes On the map, the gliding site warns of glider towing to a height of 2400feet above mean sea level and the height of the airfield is 320 feet AMSL. The 2km circle is a warning of winch launching to other airspace users. It is not a prohibited or restricted area and is not the property of Needwood in terms of airspace.

ICAO 1: 500 000 map showing Tatenhill and Cross Hayes (Needwood Forest GC). Map edition for illustrative purposes only

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Needwood circuits to land Rwy 28

When landing to the West, the proposed turbine, although close to the circuit downwind leg, will be well below the glider circuit height, which should ideally be 650 feet above the landing area at that point.

Needwood circuits to land Rwy 10

When landing to the East, the turbine would again lie close to the circuit downwind leg which would be expected to remain well within the orange path over the ground on the diagram, which is shown at approximately 1000 metres South of the landing runway. Closer circuits would be expected on a day when the thermals used by glider pilots to gain energy would also be generating sinking air in other places. According to BGA practice, gliders at this point should be more than 500 feet (150 metres) above the landing area. Any approaches below that height (emergency circuits) would be flown closer to the field. J and S Bostock Page 27 of 31 RJC

When there is a northerly component to an easterly wind, pilots can be expected to fly even closer to the landing areas than the orange pattern. However, in relatively calm conditions, or with a gentle southerly component, there is a possibility that pilots may follow a wider pattern, perhaps closer to that depicted in yellow, which could bring their path overhead or slightly outside the proposed turbine (with it in clear sight). However, it is extremely unlikely that a glider would be as far away from the landing area on its downwind leg as the yellow route indicates, unless it was higher than normal. At that distance of one mile, if the glider was at a height of 600 feet, the field would subtend an angle of only 10 degrees, which is not a very comfortable angle for a glider pilot. Nevertheless, a southerly component in the wind might encourage a pilot of a high performance glider to be in that position at normal circuit height. If a pilot flies the wide yellow pattern in a modern high performance glider, he should be at his final turn point to line up at a minimum of 300 feet above his landing point. Pilots are never perfect so one should assume they reach 300 feet during the turn. At a glide angle of 1 in 60 (unattainable with the gear down by any current sailplane, but a 'worst case' scenario with a Southerly wind), that pilot will be at or above 500 feet above Needwood when flying past the proposed turbine. He should be starting his subsequent 45 degree turn, abeam his landing area above 500 feet but, as said, pilots are not perfect. However, if lower, he should have moved closer to the field during the downwind leg, taking himself inside the turbine and clear of it, and the normal pilot training to do this provides a major risk mitigation. Even in poor visibility, the risk of contact with the turbine or its blades is very slight if the blade top is below 300 feet above Needwood and this is the height of the proposed turbine above ground, which at the turbine site is 10 metres lower than the glider landing area. In normal visibility, the turbine would be obvious to all pilots approaching the glider field, and a pilot would naturally aim to avoid flying directly over it. It would be a natural reaction to aim to make ones circuit pattern inside it, which is where the normal circuit pattern would be expected, unless the pilot was well above the top of it. In poor visibility, a pilot would tend to fly closer to his landing area. However, glider pilots do occasionally land around dusk and at that time the wind tends to have dropped, thermal turbulence has ceased, and the wider circuit is perhaps more likely to be flown. Providing some lighting of the turbine to attract pilots attention at those times would mitigate the risk, and may also be valuable during overcast conditions. Authors Note: The applicants have lived in Braddocks Farm for twenty years and have always seen gliders operating to the North of their property and not to the South in the circumstances shown on the maps on Page 27. J and S Bostock Page 28 of 31 RJC

 Item 2 Gliders Soaring. The only claim for safeguarding rests with Needwood because it is within 2km of the turbine. Gliders ridge soaring or on their way to a ridge soaring area are normal en-route traffic and responsible for their own safety through see and avoid, planning, airmanship etc. As en-route traffic, gliders soaring or transiting are subject to the 500 foot Rule and must avoid the existing wind turbine. In practice, the area near the turbine is likely to be unsuitable as a soaring site due to the broken ground in all directions reducing the likelihood of lift in the area. Gliders transiting to other ridge locations are unlikely to be below 500ft in the vicinity of the proposed turbine. Item 3 Transiting light aircraft traffic contacts turbine. The situation here is similar to that for gliders transiting with the added protection that aircraft other than gliders from Needwood are requested to avoid the glider site annotated on the CAA flying charts. Needwood uses a cable winch to launch gliders up to 2000feet and this is considered to be a greater hazard than the wind turbine. Any argument that transiting aircraft could be lost and fly into the turbine is equally applicable to the cable at the glider site. Restating how aircraft fly under Visual Flight Rules; - it is the pilots responsibility to look out for other aircraft and obstructions and to avoid them. The minimum visibility of 1500m must be maintained and any aircraft flying under Instrument Flight Rules in a visibility of less than 1500m will be well above the height of the turbine, as it must maintain the minimum safe height for the area. Item 4 Military low flying aircraft contacts turbine. The discussion points for transiting civil light aircraft also apply to military aircraft. Military low flying is subject to detailed planning before the flight takes place. Informing the Military Aviation Authority of the existence of the turbine before construction begins should provide notification and include the turbine as a feature to be avoided, not only at the planning stage but also during flight when the crew refers to the map.

J and S Bostock

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Conclusion
This assessment concludes that the erection of a 75m wind turbine near Hamstell Ridware: 1. Generally, will have minimal effect on gliders operating from Needwood Forest gliding site or for other aircraft transiting through the area. It will be the pilots responsibility to avoid the turbine as it is for any other en route obstacle. The 2km circle shown on the map around the gliding site already warns other airspace users of the gliding activity and winch cable and this will keep other aircraft clear of the turbine. 2. Specifically, will have a minor effect on Needwood Gliding site. Under some lighting conditions the turbine structure may be difficult to see or could be forgotten through familiarity. There may be a case for a warning light on top of the turbine, but it is unlikely that gliders will be operating in such conditions. It is stressed that the risk is considered acceptable without this addition. Neither of these conclusions should preclude the erection of a wind turbine near Hamstell Ridware on grounds of aviation safety. The Risk Analysis does not highlight any risk requiring mitigation other than normal aviation practices such as NOTAMs and adherence to the Rules of the Air. However, the turbine could be made more visible if this is acceptable on other planning grounds. That said, there is no requirement for an en-route obstacle to be lit if it is under 150m tall (Article 128 of the ANO refers, See Page 11).
Digitally signed by Bob Commander DN: cn=Bob Commander, o=Commander Aviation Services Ltd, ou, email=bob@commanderaviations ervices.com, c=GB Date: 2012.03.19 10:17:18 Z

Bob Commander

J and S Bostock

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CAA Advice
While this report is based entirely on the opinions of the author, advice has been sought from the CAA. The CAA has offices in London and Gatwick as well as regional offices around the country. The London office houses the Directorate of Airspace Policy (DAP) while Gatwick is home to Safety Regulation Group (SRG). DAP is responsible for the planning and regulation of all UK airspace including the navigation and communications infrastructure to support safe and efficient operations. DAPs Airspace Utilisation Section is the focal point for the integrated use of airspace, including permissions where required under the ANO as mentioned in this report. SRG sets certain national safety standards. In parallel, it oversees the activities of the aviation community and its level of compliance with both national and European safety standards. In particular, the Flight Operations Department of SRG includes a section devoted to General Aviation matters: Flight Operations Inspectorate- General Aviation Safety Regulation Group Tel: 01293 57 3525 Fax: 01293 57 3973 mailto:GA@caa.co.uk

National Air Traffic Services (NATS) are responsible for NOTAMs and provide the Aeronautical Information Service described in this report. Bob Commander Tel: 01342 718879 13 February 2012 Company Reg: 6707598

Commander Aviation Services Ltd

info@commanderaviationservices.com

J and S Bostock

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