Wind turbine proposal interferes with ORH approaches

George Clark writes: ... Eric Waldron contacted me to let us know that the FAA is considering a proposal by the Tersian Carmelites to install a large wind turbine on Asnebumskit Hill, 2 NM northwest of the Airport. The proposed turbine will extend 425 feet AGL (1690 MSL), and the FAA has determined that any height exceeding 200 feet would be a Hazard to Air Navigation.

https://oeaaa.faa.gov/oeaaa/external/searchAction.jsp?action=displayOECase&oeCaseID=558373

The changes to instrument approaches would be significant. Click read_more for details

I'd also consider it a VFR hazard. On busy days, I've had my downwind leg extend towards Asnebumskit hill or even beyond. At 1690, that's not very much margin for error. And for the departure minimums, 612'/NM is a rate of climb of over 900 FPM with a 90 Knot groundspeed.

Deadline for comments is Wednesday 8/6/2008 Comments must be relevant to the effect the structure would have on aviation, must provide sufficient detail to permit a clear understanding, and must contain the Aeronautical Study No. 2008-ANE-100-OE, and must be received on or before the 6th. Comments can be submitted electronically at https://oeaaa.faa.gov/oeaaa/external/searchAction.jsp?action=displayOECase&oeCaseID=558373 (Create an account and log in to comment) or in writing to: Federal Aviation Administration; Air Traffic Airspace Branch ASW-520; 2601 Meacham Blvd. Fort Worth, TX 76137-0520

FAA Documents:

• Wind_Turbine_Notice.pdf
• Wind_Turbine_Hazard_Notice.pdf

to see Eric Waldron's letter

• Runway 29 takeoff minimums increase:
  • Current: 300' with 2 mile visibility or standard with 250'/NM climb gradient to 1,300'
  • Revised: 700' with 3 mile visibility or standard with 268'/NM to 2,000'.
• Runway 33's minimums increase
  • Current: 700' with 2 mile visibility or standard with 320'/NM climb gradient to 2,000'
  • Revised: 700' with 2 miles or standard with 612'/NM climb gradient to 2,000'.
• Four approach minimums would be increased -
  • RNAV Runway 29 minimums would increase from 1,361' to 1,616';
  • GPS Runway 33 minimums would increase from 1,340' to 1,680'
  • NDB Runway 11 minimums would increase from 1,680' to 2,020'
  • The circling approach minimums for Category D aircraft would increase from 1,720' to 2,040'.

Subject: Wind Turbine Proposal that Would Raise ORH minimums

All:

As interested and important users of Worcester Regional Airport, we are writing to inform you of a proposal to construct a 425' wind turbine approximately 2 nautical miles northwest of Worcester Regional Airport. The FAA has recently released an Aeronautical Study 2008-ANE -100-OE (copy attached) related to this proposal. In the Study the FAA concludes that the wind turbine proposal will affect both instrument approach and departure procedures to Worcester Airport Runways 29 and 33. The FAA has determined the proposed wind turbine to be a "presumed hazard", and has opened a public review process in which airport users and individuals can provide comments.

The Massachusetts Port Authority (Massport) who operates the airport on behalf of the City of Worcester, has reviewed the circularization of Aeronautical Study 2008-ANE -100-OE (file attached) and will be submitting a response letter regarding the proposed facility to the FAA.

As outlined in the FAA circularization, the proposed 425' wind turbine would have a top elevation of 1,690' Mean Sea Level (MSL). The airport's elevation is 1010' MSL. The FAA analysis of the wind turbine shows that

1. Two 40:1 departure surfaces are impacted - Runway 29 takeoff minimums increase from 300' with 2 mile visibility or standard with 250'/NM climb gradient to 1,300' to 700' with 3 mile visibility or standard with 268'/NM to 2,000'. Runway 33's minimums increase from 700' with 2 mile visibility or standard with 320'/NM climb gradient to 2,000' to 700' with 2 miles or standard with 612'/NM climb gradient to 2,000'.

2. Four approach minimums would be increased - The RNAV Runway 29 minimums would increase from 1,361' to 1,616'; the GPS Runway 33 minimums would increase from 1,340' to 1,680'; the NDB Runway 11 minimums would increase from 1,680' to 2,020'; and the circling approach minimums for Category D aircraft would increase from 1,720' to 2,040'.

As you are aware, the airport is an important transportation facility that serves the Greater Worcester Region and supports the economic development initiatives within the region. As an interested Airport user, it is important that you review and if you chose respond to the FAA Study. The deadline to submit a comment to the FAA is August 8, 2008. The process to submit a comment is provided in the attached FAA circularization document and may be done via mail or electronically. The FAA also provides an opportunity to submit comments electronically at https://oeaaa.faa.gov/oeaaa/external/portal.jsp. The FAA's designation for this project is Aeronautical Study 2008-ANE -100-OE.

If you have any questions please contact me directly at (508) 799-1350 or Mr. Jorge Panteli at 617- 568-3949.

Sincerely,

Eric N. Waldron, A.A.E., ACE

Airport Director

Worcester Regional Airport

Jorge E. Panteli

Economic Planning & Development Department

Massachusetts Port Authority

One Harborside Drive, Suite 200S

East Boston, MA 02128

T: 617.568.3949

F: 617.568.3518

C: 617.594.4307

Comments

I posted the following response to the FAA:

I am very concerned about the proposed increases in approach & departure minimums that would be required at ORH if the proposed structures are approved.

I believe that the structures will be a hazard not only to IFR, but to VFR traffic as well. During busy periods, the downwind leg of traffic on Rwy 29 and 33 can often extend near or even beyond Asnebumskit hill. Structures only a couple of hundred feet below a busy pattern will represent a considerable hazard to safe VFR operation as well.

As far as the Instrument approaches:

- 700/3 departure minimums for Rwy 29 will prevent departures on the primary runway during significantly more conditions greatly restricting usability of ORH. It is approaching VFR minimums.

- Rate of climb for Rwy 33 departure is high and might be an issue for heavily loaded aircraft or during high density altitudes.

- Category D circling minimums are essentially VFR ceilings. This would have an adverse impact on larger high performance business or cargo aircraft.

- NDB minimums are also essentially VFR ceilings. It is important that NDB approaches remain available for training purposes and continuing currency.

Worcester is a demanding IFR airport due to the elevation, and anything that increases the minimums is a significant impact to the airport. Federal money has been spent or being proposed to be spent on approach improvements to lower minimums and this would be counter-productive to those efforts.

The primary prevailing wind runway is Rwy 29, and the shorter 33. In light wind conditions, runway 11 could be used, however full length departures require significant back-taxi on the runway which is also a safety consideration.

Note that I am Vice President of the Worcester Area Pilots Association. While the above comments are mine, they also are consistent with the concerns of our organization.

We strongly recommend that this structure and the increased minimums NOT be approved.

Thanks. George Clark

-- GeorgeClark - 06 Aug 2008

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-- GeorgeClark - 02 Aug 2008