RESIDENTS AGAINST THE WINDFARM

FRODSHAM MARSH WIND FARM PUBLIC

INQUIRY

PROOF OF EVIDENCE

AIRPORT OPERATIONS

Prepared By: Tony Hinkins

Revision: Issue 1 Date: 13 October 2011

1. SUMMARY

The only realistic solution to the severe threat posed by this application to the safe
operation of two important regional airports would involve a significant development in
the Green Belt and major expenditure.

2. LIVERPOOL JOHN LENNON AIRPORT AND CHESTER HAWARDEN

AIRPORT

Liverpool John Lennon Airport (LJLA) is a first-class regional airport and its services are
highly valued locally. The proposed wind farm cannot be allowed to compromise its
operational capability, its safety or its financial stability.

Chester Hawarden Airport (CHA) is of national importance as the base for a major
aerospace contractor’s Airbus projects and its future must not be compromised. There is
also a considerable amount of corporate and light aircraft activity at CHA.

For simplicity, the analysis below concentrates on the LJLA situation with references to
the CHA situation.

3. AIRPORT RADAR SYSTEMS

LJLA uses both primary (PSR) and secondary (SSR) surveillance radar systems.

In an SSR system the outbound radar signal is received by an aircraft which then
transmits a coded reply (through a “transponder”) back to the radar station. The coded
reply will often include additional information such as altitude and callsign. An aircraft
not equipped with a transponder will be invisible to Air Traffic Services (ATS) under a
SSR-only system

A PSR system is frequently used in conjunction with SSR and sometimes as a stand-
alone system. In a PSR system radio energy is reflected off the tracked aircraft back to
the radar station which, in turn, computes position. The advantage of PSR is that the
aircraft does not have to carry a transponder. Military aircraft sometimes have
transponders turned off for tactical reasons and light aircraft are sometimes not equipped
with operational transponders. Microlight aircraft, gliders, and hot air balloons very
seldom carry transponders.

A PSR system allows Air Traffic Control to use lower horizontal separation criteria
between aircraft and less conservative background procedures, resulting in a more
expeditious air traffic flow.

PSR has much higher energy requirements than SSR.

4. THE RADAR PROBLEM

A SSR system can suffer from wind farm interference due mainly to signal reflections.
Modern systems overcome this by the use of predictive track software and other tools.
Additionally many airports “buy in” SSR data from a remote antenna (LJLA’s is in
Lancashire). Thus SSR problems are largely irrelevant to the proposed development.

The problems of PSR and wind farms are well documented. Due to the doppler shift
created by rotating wind turbine blades, the radar receiver confuses a wind turbine for a
moving aircraft. Often great swathes of unwanted radar returns (clutter) will appear on
the radar operator’s display over the entire sector of the wind farm, through which
nothing can show. “Shadow” returns can appear in the lee of the wind farm and much
radar energy is attenuated in the process.

The applicant accepts that the wind farm will cause a clutter effect on the existing PSR
systems at LJLA and CHA (Ref. 1).

5. FLIGHTPATHS

5.1 Light Aircraft

The Helsby / Frodsham area is heavily used by light aircraft entering and leaving the
Liverpool Control Zone:

• The “Oulton Park” Visual Flight Rule (VFR) arrival procedure (Apps. 1 and 2) uses
the airspace directly above the proposed wind farm as a holding point from where light
aircraft are directed into the LJLA traffic pattern. This arrival procedure has an altitude
limit of not above 1500 feet.

• Light aircraft entering Liverpool airspace via Chester will frequently be directed to
Frodsham Marshes to hold and wait for sequencing to land at LJLA.

• Frodsham Marshes are also frequently used as a holding area for light training aircraft
flying circuit patterns to LJLA.

• Light aircraft such as police helicopters, spotter aircraft and pipeline inspection flights
frequently depart and arrive CHA on a northerly route, following the M56 motorway
adjacent to the proposed wind farm to join the Low Level Corridor at Warrington.
Typically they cross Frodsham Marshes at altitudes not exceeding 1000 feet.

The Aircraft Owners and Pilots Association, which represents typically the users of light
aircraft, has objected to the proposal on the grounds of flight safety (Ref. 2).
5.2 Commercial Aircraft

Commercial aircraft arriving from the south frequently overfly Frodsham Marshes when
visually positioning for landing on LJLA Runway 27 (westerly direction - used most of
the time). Figure 1 provides a glimpse of the situation.

Figure 1: LJLA Movements 3 June 2006 (LJLA Master Plan 2030)

When Runway 09 (easterly direction) is in use, nearly all commercial aircraft departing to
the south overfly Frodsham Marshes to comply with the Standard Instrument Departure
(SID) procedure (Apps. 3 and 4).

Aircraft using the Instrument Landing System for Runway 22 at CHA will do so under
the guidance of LJLA approach control services typically up to the point the aircraft is
directly overhead the proposed wind farm, when they are handed over to the CHA
approach service.

5.3 Overflying Aircraft

Due to the proximity of Manchester airport and the resultant high traffic density, there is
very little flexibility to vary of any of the above procedures.
6. CURRENTLY AVAILABLE SOLUTIONS

6.1 Tilting the PSR Aerial

The Belfast International Airport PSR aerial was tilted to 1.5 degrees in azimuth in order
to reduce unwanted clutter from a nearby ridge and wind farm. Given the proximity of
the wind farm to the LJLA radar aerial and the height of the proposed turbines, the LJLA
radar would have to be tilted at least 1.5 degrees to achieve the same result. There would
then be large areas to the west and north west of the airport that would lie beneath
primary radar cover. Low flying aircraft without transponder equipment would therefore
be denied help or guidance in the event of poor weather conditions or safe passage into or
around controlled airspace.

CHA would be affected in a similar manner due to similar technical challenges.

To effect this fix would involve a prolonged period of radar outages for both airports and
expensive recalibration measures. It is highly unlikely that such a measure would meet
with the approval of the relevant ATS providers.

6.2 Range Azimuth Gating

Range Azimuth Gating (RAG) is the technical term for blanking the sector of clutter from
showing on radar displays. This is a highly undesirable work around. RAG is a crude
tool: it blanks the area of the source of clutter (wind farm) itself but also generates
significant fade areas over and behind the source of clutter. Given that the wind farm
would be a mere 3nm from the radar antenna and encompass a sector of approximately 25
degrees, it would mean a large segment of high traffic density with no PSR coverage for
both LJLA and CHA. It is highly unlikely RAG would be deemed an acceptable solution
to the relevant ATS providers.

6.3 Moving Target Detection

In 2006 LJLA replaced its existing PSR with Raytheon ASR-10SS Mk2 equipment. This
is a sophisticated and popular system used by many airports worldwide. The ASR-10SS
uses a system called Moving Target Detection (MTD), together with doppler signal
processors, to help eliminate clutter.

Wind farm generated clutter is still a major issue worldwide, even at sites where MTD
has been installed. There is no evidence to suggest the situation at LJLA would be any
different. No direct comparison can be made with any other site as the location and
physical characteristics of every wind farm and radar are different from one another.

6.4 Discontinue PSR Services at LJLA and CHA

A move to “SSR only” airspace (an option suggested by the applicant) would severely
curtail airport operations. Minimum separation distances between aircraft would have to
be increased and more conservative flight procedures adopted, thus reducing the airport’s
capacity at peak periods. It would also increase fuel consumption and hence carbon
emissions.

The Liverpool control zone would be denied to some light aircraft, pipeline inspection
helicopters, etc that might not be equipped with an operational transponder.

When Belfast International Airport’s PSR was unserviceable for four months in 2010,
due to a planned outage, it resulted in significant flight delays and major fuel wastage.

Currently the only portions of UK airspace that are designated “SSR only” are high level
airways entering North Atlantic airspace and the airspace above two offshore wind farms
that do not regularly encounter light aircraft. The Civil Aviation Authority does not
currently authorize “SSR only” airspace in Terminal Maneuvering Areas or in an
approach environment (Ref. 3), both of which apply to the area in question.

6.5 Install an Infill Radar

This is currently the only proven solution that will not compromise services.

An infill radar is another PSR (Figs. 2 and 3) installed, typically, in the lee of a hill that is
close to the source of the clutter. The infill radar looks over, but does not make line of
sight contact with, the turbine blades. The original primary radar can then have that
segment blanked from display.

Figure 2: PSR Radar Antenna

Infill radar has been used successfully at several UK wind-farm-affected sites, an

example being that installed to cover Whitelees Wind Farm on Eaglesham Moor,
Scotland, which was creating clutter on the Lowther PSR used by both Prestwick and
Glasgow ATS.
 Figure 2: PSR Radar in a Weather Protection Housing

The logical site for such a facility would be in the lee of the escarpment running from
Frodsham to Alvanley. Such an installation in this area would clearly raise issues in an
area of Green Belt with designated high landscape quality (Ref. 4).

The capital cost of such a system is in the order of £6million and the running cost in the
order of £400,000 pa (Ref. 5).

7. TECHNOLOGIES UNDER INVESTIGATION

Interference with air traffic control radar is a huge problem for the wind energy industry.
Vestas estimate that 20GW of wind farm capacity is currently held up globally by this
one issue. Hence there is a massive drive to find a solution but Raytheon, a major global
radar supplier which provides LJLA’s current system, recently briefed (Ref. 6) that:

“Currently there is no known, certified, cost-effective, silver bullet solution, based on our
extensive field exposure”

Two areas of technology are under investigation:

• Stealth Technology Vestas recently gave a positive briefing on the testing of a rotor
coated with “a similar material to that used to make stealth bombers invisible to
radar”. However there is world of difference between a satisfactory “proof of concept”
test and the availability of a commercial turbine with the desired features. There are
obvious cost, weight, durability and aerodynamic efficiency (the Northrop Grumman
B2 stealth bomber is an aerodynamically inefficient aircraft) issues to be addressed.
Stealth technology attenuates radar signals and produces “fade areas” which hide other
objects in the vicinity. Would the appearance of a “stealth” turbine be acceptable:
stealth bombers look distinctly different to conventional bombers? What would be its
noise characteristic?

• Radar Improvements These investigations cover hardware changes to existing

equipment, new technology radar equipment and software upgrades to existing
 equipment. Some ideas being investigated include: clutter maps for doppler processors
incorporated with digital optimization and enhanced tracking techniques (software),
concurrent beam processing (modified radar aerials and software), and 3D holographic
radar (new technology). The huge variety of ideas under investigation indicates that
the work is at an early stage and there is, at present, no clear “front runner”. In
addition, any proposed solution will have to undergo rigorous testing and validation
prior to its use.

Very significant resource is being committed to trying to find a solution to this problem
but that does not mean that a solution exists. In reality we are no nearer a solution than
when, in 2008, counsel for a UK airport operator said (Ref 7):

“…it is submitted that no mitigation strategy has been (a) devised, (b) proven or (c)
secured with anything approaching the level of precision and certainty which would be
necessary to allow permission to be granted…the complete absence of a “quick fix”
solution in this case is amply demonstrated by the extraordinarily diverse range of
approaches to the aviation issues…”

8. PLANNING CONDITIONS

On some wind farm applications, consent has been conditioned on a satisfactory

resolution of the radar issue.

The threat of Frodsham Marsh Wind Farm has already hung over the local community for
two years. The radar problem may never be resolved. If it were to be resolved, it would
be several years before suitable equipment was commercially available.

Such long-term “planning blight” is deeply harmful to the local community.

9. DISCUSSION

The radar problem has been obvious for many years and is well understood by the
industry.

A technical solution is readily available: a new primary infill radar. This application
should be assessed on the planning parameters of that solution, which would involve a
significant physical installation in the Green Belt on the Mid Cheshire Ridge and
significant costs.

Alternative solutions are extremely diverse, currently only at the “proof of concept”
stage, and many years away from commercial availability. Given the current state of play,
it seems highly unlikely that any alternative solution will be available to enable
equipment to be designed, installed, tested, approved by the authorities, and supplied to
LJLA and CHA in time for development to commence on site within the three year
period normally allowed by any approval. In such circumstances a “planning conditions”
approach is inappropriate because of:

• the extended period of “planning blight”

• the uncertainty of ever finding a solution
• the complete uncertainty regarding the planning parameters of any solution

A “planning conditions” solution would not be considered for the resolution of a major
physical issue, eg the height of a block of flats, and it is no more acceptable here just
because the problem is more difficult to understand.

10. CONCLUSION

The only currently-available solution to the radar problem which would maintain the
current operational capabilities of these two vitally important regional airports involves
installing a radar antenna in a sensitive area of the Green Belt and significant additional
costs. Alternative solutions have not yet advanced to the stage of definition required for
consideration by the planning process.

11. REFERENCES

1 Peel Statement of Case, September 2011: Page 24

2 Undated letter “Frodsham Marsh Windfarm - Liverpool John Lennon Airport” from
David Ogilvy, Aircraft Owners and Pilots Association to Secretary of State, DECC

3 Civil Aviation Authority: CAP 764 - CAA Policy and Guidelines on Wind Turbines,
February 2009

4 Vale Royal Borough Council: Local Plan, First Review Alteration, 16 June 2006

5 Figures are based on estimates for a number of UK capital projects: Ronaldsway

£3.5m; Jersey £4m; Kincardine £8m; Prestwick £10m. Kincardine/Prestwick estimate
a running cost of £400,000 pa.

6 Raytheon Systems: “Overview of Raytheon Wind Farm Mitigation Techniques and

Test Results”, 15 June 2011

7 Northumberland (Green Rigg / Ray / Steadings) Wind Farms Public Inquiry: Closing
Submissions on behalf of Newcastle international Airport, Ref NIAL/0/11
 APPENDIX 1

JEPPESEN VFR AREA CHART (LIVERPOOL)

 APPENDIX 2

JEPPESEN VFR GENERAL AERODROME INFORMATION (LIVERPOOL)

 APPENDIX 3

JEPPESEN EGGP 10-3B (LIVERPOOL)

 APPENDIX 4

JEPPESEN 10-3D (LIVERPOOL)