Windfarm Threat at Popham

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John Brady
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Windfarm Threat at Popham

Post by John Brady » Mon May 20, 2013 6:50 am

The owner of Popham Airfield, has sent the email below asking for help about an application to build a wind farm close to Popham Airfield. You may want to oppose the application using the links on the very helpful website http://www.keephampshiregreen.org The closing date is this Friday 24 May.

We suggest you send emails to the 3 planning authorities listed in the link. You may want to refer to the following powerful government policy statement which can be used in support of aviation and flying sites against inappropriate development in your comments:

The National Planning Policy Framework (NPPF) which local authorities have to comply with has a footnote 17 on page 22 which specifically directs decision makers to the Overarching National Policy Statement for Energy Infrastructure (EN-1) which, at paragraph 5.4.2 states: “It is essential that the safety of UK aerodromes, aircraft and airspace is not adversely affected by new energy infrastructure.”

Email from Susanna Church:

Bullington Cross Wind Farm – Threat to Popham

EDF have submitted their application for the 14 wind turbines. We have only one week left to respond officially. Last day is 24th May. We are hoping for an extension, but this is not confirmed.
Could you please ask your members to write a letter now to the 3 councils, if they would like to help "Save Popham Airfield".

If they look on the http://www.keephampshiregreen.org website, it will tell them what must go into their letter of protest, it need not be too long, just heartfelt. If these awful things are erected beside my home and farm, it is likely that I will have to move, for the sake of my health. Popham would probably have to close, as it is part of the estate. I do not want that to happen. Anything you and your members can do will help us.

Thank you for all you have done so far.

Kind regards.
Susanna B Church
Popham Airfield
031926

James Chan
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Re: Windfarm Threat at Popham

Post by James Chan » Mon May 20, 2013 2:31 pm

I've been looking for more information about how this may be a threat to Popham.

Is there any ACTUAL evidence to suggest how the exact placement of these SPECIFIC turbines would impact aviation safety for flights in and out of Popham? How has the windfarm 4-5nm west of Lydd affected them?

Personally I cannot see how they could put a wind farm beside an operational aerodrome and get away with it. But then again, who allowed a petrol station to be built on final so that aircraft have to fly an offset approach?
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mikehallam
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Re: Windfarm Threat at Popham

Post by mikehallam » Mon May 20, 2013 4:02 pm

Because the petrol station was there before Jim Espin demolished the woodland !

mike hallam (OAP)

John Brady
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Re: Windfarm Threat at Popham

Post by John Brady » Tue May 21, 2013 10:37 pm

More information is avaiable in this masterful submission by Steve Slater on behalf of the GAAC
John

Dear Mr. Dimon.
I have been asked to comment on the recent planning application for the construction of wind turbines up to 126.5m in height, as part of a single wind farm of 14 wind turbines at Bullington Cross, Upper Norton Farm, Sutton Scotney, Hants SO21 3QF.

I would like to formally object to the application on the grounds of its impact on air safety and future flying operations from the established airfield at Popham and the private flying site at Roundwood House. Please accept the attached as plain text. I have also attached as a pdf file, a formal letter for your records.

As I understand that this development is the subject of three separate planning applications, this objection is being placed simultaneously with Basingstoke and Dean Borough Council (13/00046/FUL), Test Valley Borough Council (13/00753/FULLN) and Winchester City Council (13/0800/FUL). May I also request please that the General Aviation Awareness Council (GAAC) and this letter of objection are placed on your Consultee Comments list.

The proposed development is less than 4km from the runways of both flying sites and is on the edge of the recommended safeguarding zone for airfields of this nature as recommended by the UK Civil Aviation Authority and the companion guides supporting the National Planning Policy Framework. The scale of the proposed multi-turbine development presents an even greater direct risk to flight safety due to likely cumulative effects of downwind air turbulence from the prevailing westerly winds and could potentially render the Roundwood Farm flying site unusable, while posing a significant hazard to aircraft climbing out after take off from runway 26, the most used runway at Popham.

I am also concerned that the turbines offer a potential safety risk to other aircraft passing above the proposed location, which is directly underneath a busy Visual Flight Rules (VFR) flight route. The airspace in the area is described by the Developer’s own aviation consultant as “probably one of the most complex aviation areas in the country”.

I write on behalf of the General Aviation Awareness Council (GAAC) and the UK Aircraft Owners’ and Pilots’ Association (AOPA UK), for whom I assist in advising on aerodrome planning matters.

The Aircraft Owners and Pilots Association UK is part of the largest association of pilots in the world, with over 470,000 members in over 50 countries. AOPA UK is a not-for-profit organisation which exists to serve the interests of its members as aircraft owners and pilots, promoting the economy, safety, utility, and popularity of flight in general aviation aircraft.

The General Aviation Awareness Council (GAAC) was formed in 1991 to promote the interests of the wide range of General Aviation activities in the UK as a national body representing the general and light aviation movement. It has assisted Government in preparing policies and offering a co-ordinated approach to major issues and is regarded as a key contributor to wind generation policy.

It is a GA industry representative on the government’s Air Safety Initiative Windfarm Working Group (ASIWWG), working with CAA, DfT, MOD, NATS, DECC and others to develop practices to ensure that wind turbines and anemometer masts do not conflict with the safe operation of aircraft.

I must stress that neither the GAAC nor AOPA is opposed in principal to wind turbine developments. Indeed we have helped a number of wind turbine developers to reach satisfactory solutions to allow developments to proceed alongside flying sites. Our objection in this case is driven entirely by the risk that this inappropriate development poses to flight safety

PLANNING POLICY

In policy terms, the requirement for general aviation airfields and other flying sites for recreational, business, training and emergency services use is reflected both in the past PPG13 and today, in the National Planning Policy Framework.
“Local planning authorities should consider the role of small airports and airfields in serving business, recreational and emergency services needs”.
“In formulating their planning policies and proposals, and in determining planning applications, local authorities should take into account the economic, environmental and social impacts on local and regional economies.”
“Local authorities should avoid development at or close to an airport or airfield which is incompatible with any existing or potential aviation operations.”

NPPF Section 3; paragraph 28 also states that: “Planning policies should support sustainable rural tourism and leisure developments that benefit businesses in rural areas, communities and visitors, and which respect the character of the countryside. This should include supporting the provision and expansion of tourist and visitor facilities in appropriate locations where identified needs are not met by existing facilities in rural service centres”

The NPPF (Paras 31, 33) additionally states that:
“When planning for ports, airports and airfields that are not subject to a separate national policy statement, plans should consider their growth and role in serving business, leisure, training and emergency service needs. Plans should take account of this Framework as well as the principles set out in the relevant national policy statements and the Government Framework for UK Aviation.”

General Aviation (GA), together with Aerial Work (AW), covers all civil aircraft activity other than that carried out by the commercial air transport (CAT) sector. It is the largest part of the UK aviation community.

Whilst commercial air transport comprises about 900 aircraft and uses 25 airports, the active GA fleet is made up of some 15,500 aircraft, including helicopters, gliders, microlights and balloons. These are flown by more than 32,000 pilots. GA in the UK uses 143 aerodromes licensed by the Civil Aviation Authority (CAA) and around 1,000 other flying sites.

Popham airfield’s grass runways have for almost three decades provided a base for around 130 aircraft, ranging from microlights and sport aircraft to executive helicopters. It also hosts a professional maintenance organisation and the busiest microlight flying school in the UK.

In addition to generating direct economic and employment benefits on its own behalf, Popham is a highly successful enhancement to the regional economy. It is one of the top twenty General Aviation airfields in the country and is regularly used as a gateway for tourism visitors to the area, as well as being utilised by business users taking advantage of its close proximity to the A34, A303 and M3 motorway. Such activity could be threatened if the proposed developments were allowed to progress.

FLIGHT SAFETY ISSUES REGARDING THE PROPOSED DEVELOPMENT

There are clear causes for concern on flight safety grounds to aircraft operating from Popham and Roundwood House. It is noted that a detailed submission, particularly demonstrating the likely effects of downwind air turbulence has been presented by The Spitfire Flying Club on behalf of Popham airfield. We are fully in agreement with this submission and therefore will not repeat their evidence in this document.

We should note however that in addition to the concerns regarding air turbulence, sadly there are proven demonstrations of the risks from tall obstructions in the vicinity of aerodromes, when aircraft are more likely to be concentrated at low level than when flying en-route between destinations. In September 2011, there was a fatal accident to an aircraft which struck the top of an electricity pylon while approaching an airfield at Sibson in Northamptonshire.

There has also been a recent fatal accident near Rotterdam in the Netherlands, of a Cessna 172 which crashed near a major wind turbine development. While the official accident report has not been published, the aircraft was flying at low level and in poor visibility and it has been deemed probable that the crash stemmed from a loss of control when late avoiding action was taken.

In addition to the concerns regarding direct collision with the wind turbines, there is a noteable concern regarding the effect of such a large group of wind turbines will have on other aircraft operating in the vicinity.

While most commercial air transport and a proportion of general aviation traffic fly to and from larger airports using predesignated routes under IFR or “instrument flight rules” conditions, the vast majority of flights within the UK are made outside controlled air space. These flights are flown under VFR or “visual flight rules” conditions, usually at lower altitudes, relying on visual navigation.

This navigation relies on following a course with reference to visual landmarks. In the case of Bullington Cross, this is a noted VRP, or visual reference point, due to the easily recognisable junction of the east-west A303 and north/south A34. It also conveniently marks the eastern edge of the Middle Wallop military air traffic control zone.

The airspace above the development therefore combines traffic in transit, both north and south, east and west, as well as civilian and military aircraft flying from Boscombe Down, Middle Wallop, Odiham, Thruxton, Popham and Lasham. In exactly the vicinity of the proposed wind turbines, pilots of GA aircraft and military helicopters must already maintain a heightened awareness (lookout) for oncoming traffic, and other traffic crossing their path left/right and right/left at the same or similar altitude.

The proposed wind turbines will offer an added threat, particularly in conditions of poor visibility, in precisely where the challenges of an added hazard to visual navigation become paramount. Perhaps the best analogy could be that the proposed turbines would be akin to erecting a tower block in the middle of a busy, ultra-fast motorway intersection.

NOISE AND CUMULATIVE DEVELOPMENT

A further issue which would be created by the imposition of the 14 wind turbines would be the effective funnelling of aircraft away from the development. This would lead to a likely increase in overflights of Whitchurch, Overton, Micheldever and Barton Stacey; something which pilots and residents alike will be keen to avoid.

In addition there are concerns that a further large-scale wind turbine development at proposed Woodmancott Down, 4km south east, with a further 8 x 135m turbines, may create a cumulative effect, condensing flying activity into a smaller space, as pilots endeavour to remain clear of the wind farms. It is noted that formal application for this development has so far been deferred, but it should nonetheless therefore be considered in wider planning strategy.

POINTS OF REFERENCE

It is noted that the developers have included an Aviation Report as a part of their planning submission. This has been prepared by Commander John W Taylor RN, the founder and Managing Director of Wind Power Aviation Consultants Limited.

Commander Taylor formed the company after a long and distinguished career as a military air traffic controller and radar specialist. It is not surprising therefore that a significant proportion of his report advises on radar spectrum interference, in which he advises that the development may indeed have a detrimental effect on military and civilian air traffic surveillance and which may be the subject of further planning and safety objections.

It is noted too that Cmdr. Taylor makes reference to potential issues regarding the downwind turbulence and visual navigation in connection with operations at Popham and Lasham. However it is also noted that the lack of detail in these areas perhaps indicates an absence of direct knowledge of light aircraft and microlight operations, such as those carried out at Popham. In particular aircraft departing the most used runway, 26, into the prevailing westerly winds, would meet potential turbulence at their most vulnerable phase of flight, in a climbing attitude at low level and at low airspeed.

Two CAA Policy and Guideline publications offer appropriate advice in this area, CAP 764 “Wind Turbines” and CAP 793 “Safety at Unlicensed Aerodromes”. The former document indicates that turbines will offer a serious risk of destabilising a light aircraft on departure or approach with the vortex air turbulence inevitably generated by the fast-moving wind turbine tips.

CAP 764, para 8.3, indicates that turbulence may occur within an area 16-times the rotor diameter of a turbine. This factor is also used by many companies within the wind generation industry as their planning standard. However this should not merely be regarded as a fixed point from the airfield boundary.

Mr Irv Lee, one of Britain’s most experienced light aircraft flying instructors, who is based at Popham has stated:

“The problem is not just the straightforward physical distance of the wind farm measured from the airfield, standard aviation practice (and safety considerations) dictate that an aircraft climbs more or less straight ahead (with small adjustments to course to avoid overflying houses) for about one and a half kilometres from the airfield and normally reaches a height above ground of approximately 500' before any major turns away from the runway direction.

“The area between the airfield and the turning point one to one and a half kilometres from the runway whilst climbing to 500' is when light aircraft are at their most vulnerable in the air due to having just taken off. This is the distance that should be considered for safety, not simply the 'crow flies' distance from any wind farm to the physical airfield.”

It should also be noted that Local Planning Authorities are only obliged to formally refer to the CAA for assessment, planning applications in the vicinity about 40 of the largest licensed aerodromes and airports in UK. For the remaining flying sites across the UK, it advises that the Planning Authority should give due consideration to the local knowledge and expertise of the airfield owner.

Its stated view is that: “An aerodrome operator is normally competent to assess the safety parameters which affect the amenity of the site, and qualified to provide expert advice to planning authorities. The comment of third parties has less value as it lacks the detailed knowledge that can only be gained by site-specific experience, and will also without the element of future planning which only the aerodrome operator will know.”

This policy is also consistent with the Government advice as published in ODPM/DfT Circular 1/2003. When asked by a planning authority to comment on the effect which a proposed new development might have on an adjacent aerodrome, the CAA advise that the aerodrome manager be consulted, and that any advice on safety so obtained may be considered expert advice.

In this respect, Spitfire Flying Club as the airfield operator, should be regarded as the prime source of expert advice on the safety of the location of the proposed development.

PLANNING PRECEDENTS

It is notable that a number of planning authorities have recently made planning decisions against inappropriate wind turbine developments affecting airfields and safe flying operations.

The rejection of similar applications on aviation safety grounds by Ryedale District Council at East Heslerton (11/00270/MFULE), by Cornwall Council (PA12/02973) in regard to a development at Bodmin, and the Scottish Office rejection of an appeal by developers at Harburnhead, have all supported airfield operators’ cases against inappropriate development.

In addition the Planning Inspectorate upheld the refusal by Wiltshire Country Council of permission for a wind turbine development close to the gliding site at Membury, while a further wind turbine proposal at Bodmin and a similar wind turbine proposal affecting a flying site at Great Heck near Selby were recently voluntarily withdrawn after similar objections were raised during consultation.

It is also noteworthy that a further recent planning precedent was set by West Oxfordshire County Council who rejected a planning application and subsequent appeal which would have affected Enstone Aerodrome, on the grounds that it would:
"Materially impact on the use of the airfield for general aviation purposes and result in the loss of an important community facility."

If required, I will be happy to provide you with more detailed information on any of these rulings.

Please therefore accept this submission as an objection to this inappropriate planning proposal.

Yours faithfully

Stephen Slater

General Aviation Awareness Council
031926

James Chan
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Re: Windfarm Threat at Popham

Post by James Chan » Wed May 22, 2013 10:44 am

An excellent letter, which has helped me understand the problem better. Thank you.
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Bob F
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Re: Windfarm Threat at Popham

Post by Bob F » Wed May 22, 2013 7:05 pm

Stephen,

Excellent submission!
Bob Farrell
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