Question

How should the SPG address MoD and aviation constraints?

We understand that Scottish Government are supporting the UK initiative, launched by the Prime Minister to identify and test technical solutions to the potential difficulties wind farms pose to air traffic and defence radar. This work is on-going and should be monitored.

This issue is being taken forward by the UK Government's Aviation Steering Group. It recognises that there is no universal solution to mitigating the effects of wind turbines on radar.

It is therefore working on a series of workable mitigation solutions endorsed by aviation stakeholders which offer the opportunity for constructive dialogue between wind farm developers and aviation stakeholders to identify, explore and implement mitigation measures to reduce the impacts of wind turbines on radar to acceptable levels.

It is hoping for some quick solutions to current problems, but in practice most of the solutions will be implemented in the next decade. New guidance on this consultation process is being prepared by the Scottish Government and should be made available soon.

Our understanding is that the focus is not so much on the Tactical Training Areas (TTA) but on impact on operational capacity and safety. The TTA are mapped and can be found from a number of sources including the DTI publication "Wind Energy and Aviation Interim Guidelines" and in PAN45. The Interim Guidelines also set out the issues on aviation and MoD and provide background reading on the subject.

The main issue for the MoD and Civil Aviation Authority is around the uncertainty of the impact of wind turbines on radar operation, particularly in relation to low flying and air defence functions. As you can imagine, the MoD and the CAA are keen to adopt a precautionary approach and, rather than create 'go' and 'no go' areas seek to maintain a case-by-case consultation approach. It is important to recognise general constraints such as airport landing and take off routes, so while  consultation with airports and MOD on the locational guidance will also be worthwhile, but the general approach of case by case consultation will remain the norm.

In terms of planning policy, as set out in SPP6: Renewable Energy, the onus is on the developer to address these impacts, and to satisfy the CAA and the MoD that potential impacts have been satisfactorily addressed. The role of the Local Planning Authority is to ensure that the CAA and the MoD are satisfied with the proposal.

This means that in policy terms the operation of aviation radar is largely a function of development control and can only have a limited spatial context. SPP6 at paragraph 4 to Annex A requires that criteria dealing with constraints should be supported by spatial policies where appropriate.  Subject to the outcome of the consultations with the relevant aviation bodies which you undertake then our view is that radar constraints are unlikely to require spatial policy support and the robustness of any such spatial policy would be likely to be the subject of considerable scrutiny by the wind development industry.  However, we would suggest that consideration is given to including a constraint criterion that ensures aviation issues are included in wind farm assessment at the application stage.