Technical Guidance for Evaluating

Selected Solar Technologies

on Airports

Federal Aviation Administration

Office of Airports
Office of Airport Planning and Programming
Airport Planning and Environmental Division (APP-400)
800 Independence Avenue, SW
Washington, DC 20591

Version 1.1
April 2018
FAA Airport Solar Guide

Version 1.1 (April 2018) Prepared by:

Federal Aviation Administration
Associate Administrator for Airports
Office of Airport Planning and Programming
Airport Planning and Environmental Division
(APP-400)
Washington, DC

Original (November 2010) Version Prepared for

the FAA by:
Harris, Miller, Miller & Hanson Inc. (HMMH)
77 South Bedford Street
Burlington, MA 01803

Stephen B. Barrett, Director of Clean Energy

Philip M. DeVita, Director of Air Quality
Robert L. Miller, Senior Vice President
Under Contract to:

CSSI, Inc.
400 Virginia Avenue, SW
Washington, DC 20024

Deborah D. Wilson, Environmental Project

Manager

Cover Photograph:
Solar Photovoltaics (PV) System
Denver International Airport

Originally published in November 2010.

Summary of Changes:

 October 2013:
o Added a warning to the cover of this guide and corresponding FAA webpage that
the FAA was reviewing sections of the guide based on the latest information
about solar glint and glare.
o Cautioned users of the guide against relying solely on the document until a
subsequent update to the glint and glare sections.

 Version 1.1 (April 2018):

o Updated Section 3.1.2, Reflectivity, to incorporate the latest information about
evaluating solar glint and glare.
o Updated corresponding references to glare throughout the document.
o Clarified the relationship between solar energy and the FAA’s Voluntary Airport
Low Emissions (VALE) program in Section 5.3.2.
o Added information about the FAA’s Airport Energy Efficiency Program to
Section 5.3.3.
o Updated FAA Contact information on Appendix A (where appropriate).
FAA Airport Solar Guide

Technical Report Documentation Page

1. Report No. 2. Government Accession No. 3. Recipient's Catalog No.
FAA-ARP-TR-10-1
5. Report Date
Technical Guidance for Evaluating Selected Solar
Technologies on Airports Published in October 2010. Updated in
April 2018.
6. Performing Organization Code
DOT/FAA/ARP/APP-400
7. Author(s) 8. Performing Organization Report No.
FAA-ARP-TR-10-1
Original (November 2010):
Plante, Dr. Jake A.*, Barrett, Stephen B.**, DeVita, Philip M. **, and
Miller, Robert L. **

Version 1.1 (April 2018):

Lawrance, Michael and Magnotta, Patrick W.
9. Performing Organization Name and Address 10. Work Unit No. (TRAIS)

* Federal Aviation Administration

Airport Planning and Environmental Division (APP-400)
800 Independence Avenue, SW
Washington, DC 20591

**Harris Miller Miller & Hanson Inc.

77 South Bedford Street
Burlington, MA 01803
12. Sponsoring Agency Name and Address 13. Type of Report and Period Covered
Technical/Unlimited
U.S. Department of Transportation
Federal Aviation Administration
Airports Planning and Environmental Division (APP-400)
800 Independence Avenue, SW
Washington, DC 20591
14. Sponsoring Agency Code
APP-400
15. Supplementary Notes

16. Abstract

Airport interest in solar energy is growing rapidly as a way to reduce airport operating costs and to demonstrate a
commitment to sustainable development. In response, the Federal Aviation Administration (FAA) has prepared
Technical Guidance for Evaluating Selected Solar Technologies on Airports to meet the regulatory and
informational needs of the FAA Airports organization and airport sponsors.

For airports with favorable solar access and economics, this report provides a checklist of FAA procedures to
ensure that proposed photovoltaic or solar thermal hot water systems are safe and pose no risk to pilots, air traffic
controllers, or airport operations. Case studies of operating airport solar facilities are provided, including Denver
International, Fresno Yosemite International, and Albuquerque International Sunport.

17. Key Words 18. Distribution Statement

FAA, Airports, Solar Energy, Photovoltaics, This document is available to the U.S. public through the
Airspace Review, Reflectivity FAA/ARP web site.

19. Security Classif. (of this report) 20. Security Classif. (of this page) 21. No. of Pages 22. Price
Unclassified Unclassified xx N/A
Form DOT F 1700.7 (8-72) Reproduction of completed page authorized

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FAA Airport Solar Guide

Acknowledgements
The FAA’s Airport Planning and Environmental Division (APP-400) wishes to thank
representatives of the following organizations for their contributions to the development of the
solar guide.

Federal Aviation Administration

Office of Airport Safety and Standards (AAS)
Office of Airport Compliance and Field Operations (ACO)
Airports Regional Environmental Specialists
Los Angeles Airports District Office
San Francisco Airports District Office
Harrisburg Airports District Office
Office of Environment and Energy (AEE-400)
Air Traffic Organization, Airspace and Aeronautical Information Management, Obstruction
Evaluation Services (AJR-322) and Environmental Programs (AJR-34)
Air Traffic Organization, Technical Operations, Infrastructure Engineering Group (AJW-W15)
Air Traffic Organization, NextGen and Operations Planning, Airport and Aircraft Safety Group
(AJP-63)
Aviation Safety, Flight Standards Service, NextGen Field Program Branch (AFS-408)
Aviation Safety, Western-Pacific Region Flight Standards Div., NextGen Branch (AWP-220)

Federal Agencies
U.S. Department of Energy

Airport Associations and Consultants

Airports Council International (ACI)
Frasca and Associates
Leigh Fisher and Associates

Electric Utilities
New York Power Authority

Special Thanks

We also wish to extend special thanks to the following individuals for their support of the project
research:
 Satish Agrawal and Don Barbagallo at the FAA Technical Center in Atlantic City, NJ (AJP-
63) for their funding support through the National Cooperative Research Program and their
technical contributions.
 Cliff Ho of the U.S. Department of Energy Sandia National Lab in New Mexico for his
technical assistance on reflectivity analysis and how it can be applied to airport PV solar
projects.
 Airport representatives that hosted HMMH project site visits: Jim Hinde (Albuquerque),
Jack Gotcher (Bakersfield), Woods Allee (Denver), Kevin Meikle (Fresno), Anthony
Kekulewela (Oakland), and Greg McCarthy (San Francisco).

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FAA Airport Solar Guide

Table of Contents
Preface ......................................................................................................... xi
1 AIRPORTS AND SOLAR ENERGY: CHARTING A COURSE ................ 1
1.1 Purpose of the Solar Guide ........................................................................1
1.1.1 What is Driving Solar Energy Development?.......................................... 2
1.1.2 How is Solar Energy Impacting Airports? ............................................... 2
1.2 Solar PV Basics ..........................................................................................3
1.2.1 Types of Solar PV Technologies ............................................................ 3
1.2.2 Energy Conversion Process and Efficiency ............................................ 4
1.3 Other Solar Power Generating Systems ....................................................5
1.3.1 Concentrated Solar ................................................................................. 5
1.3.2 Solar Thermal Hot Water ........................................................................ 7
1.3.3 Transpired Solar Collectors .................................................................... 9
1.3.4 Compatibility of Solar Generating Systems with Airports ....................... 9
1.4 Photovoltaic Designs for Airports .............................................................10
1.4.1 Roof-mountings .................................................................................... 11
1.4.2 Ground Mountings ................................................................................ 12
1.4.3 Tracking ................................................................................................ 13
1.4.4 Remote Systems .................................................................................. 14
1.5 Solar PV Supply and Demand ..................................................................14
1.5.1 Supply – Solar Resource and Other Weather Factors ......................... 14
1.5.2 Electricity Demand ................................................................................ 16
1.6 The Electrical Grid ....................................................................................16
1.6.1 System Infrastructure............................................................................ 16
1.6.2 Electricity Transactions ......................................................................... 17
1.6.3 Solar Grid-Tie System .......................................................................... 19
1.6.4 Distributed Generation and Its Benefits to the Grid .............................. 19
Case Study #1 – Deploying Different PV Designs: Denver International
Airport – Pena Boulevard and Fuel Farm Projects – Colorad ................20
2 DESIGN CONSIDERATIONS: PLANNING AND SITING SOLAR
FACILITIES .......................................................................................... 23
2.1 Solar PV Project Life Cycle ......................................................................23
2.1.1 Siting and Feasibility ............................................................................. 23
2.1.2 Design and Permitting .......................................................................... 23

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FAA Airport Solar Guide

2.1.3 Installation ............................................................................................. 23

2.1.4 Operations and Maintenance................................................................ 24
2.1.5 Decommissioning/Re-commissioning................................................... 24
2.2 Project Participants ..................................................................................24
2.2.1 FAA Airports ......................................................................................... 24
2.2.2 Airport Sponsor ..................................................................................... 25
2.2.3 Utility ..................................................................................................... 25
2.2.4 Private Developer ................................................................................. 26
2.2.5 Installer ................................................................................................. 26
2.2.6 Financier ............................................................................................... 26
2.2.7 Other ..................................................................................................... 26
2.3 Airport Land Use and Safety Planning .....................................................26
2.3.1 Lands and Buildings ............................................................................. 27
2.3.2 Airport Design Standards...................................................................... 29
2.3.3 Consistency with Aviation and Airport Activities ................................... 30
2.3.4 Consistency with the Master Plan and Airport Layout Plan .................. 31
2.3.5 Airport Layout Plan Approval ................................................................ 32
2.3.6 Land Release Approval ........................................................................ 32
2.3.7 Environmental Screening...................................................................... 33
Case Study #2 – A Unique Siting Example: Fresno Yosemite
International Airport (FYI) – California ....................................................34
3 REGULATORY AND SAFETY REQUIREMENTS FOR SOLAR
PROJECTS: MEETING AIRPSACE AND ENVIRONMENTAL
STANDARDS ....................................................................................... 35
3.1 Airspace Review .......................................................................................35
3.1.1 Airspace Penetration ............................................................................ 37
3.1.2 Reflectivity............................................................................................. 38
3.1.3 Communication Systems Interference .................................................. 42
3.2 Environmental Review ..............................................................................42
3.2.1 NEPA .................................................................................................... 42
3.2.2 Examples of Potential Environmental Issues........................................ 44
3.3 Off-Airport .................................................................................................45
Case Study #3 – Evaluating Airspace Issues: Metropolitan Oakland
International Airport – California .............................................................47

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FAA Airport Solar Guide

4 AIRPORT SOLAR ECONOMICS: UNDERSTANDING THE FINANCIAL

INCENTIVES THAT MAKE SOLAR COST-EFFECTIVE ...................... 48
4.1 Cost of Electricity ......................................................................................48
4.1.1 Conventional Electricity......................................................................... 48
4.1.2 Solar Electricity ..................................................................................... 50
4.1.3 The Power Purchase Agreement ......................................................... 51
4.2 Financial Incentive Programs to Lower the Cost of Solar ........................52
4.2.1 Renewable Portfolio Standards ............................................................ 53
4.2.2 Renewable Energy Credits ................................................................... 54
4.2.3 Tax Credits ........................................................................................... 54
4.2.4 Government Grants and Rebates......................................................... 55
4.2.5 Feed-In Tariff ........................................................................................ 56
4.2.6 Bonds.................................................................................................... 57
4.2.7 Net Metering ......................................................................................... 58
4.3 Ownership Models ....................................................................................59
4.3.1 Private Ownership – Airport as Host..................................................... 59
4.3.2 Public Ownership – Airport as Owner ................................................... 61
Case Study #4 – Partnering with a Private Developer: Meadows Field –
Bakersfield, California ............................................................................64
5 THE FEDERAL ROLE IN AIRPORT SOLAR DEVELOPMENT ............ 66
5.1 Executive Orders for Energy Management and Sustainability .................66
5.2 FAA Policy and Planning ..........................................................................67
5.2.1 Possible Strategies for Solar Development ...................................... 68
5.2.2 FAA Airport Engineering Guidance....................................................... 68
5.2.3 Airport Sustainability Planning .............................................................. 68
5.3 FAA Airport Funding .................................................................................69
5.3.1 AIP and PFC Programs ........................................................................ 69
5.3.2 VALE Program ...................................................................................... 70
5.3.3 FAA Airport Energy Efficiency Program................................................ 70
5.4 Recommendations ...................................................................................70
Case Study #5 – Building on Local Initiatives: Albuquerque International
Sunport – New Mexico ...........................................................................71
Appendix A. FAA Contact Information .................................................... A-1
Appendix B. Existing Airport Solar Projects and Contact ...................... B-1

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Appendix C. Private Developer Ground Lease Example (Denver) ......... C-1

Appendix D. Power Purchase Agreement Example (Denver) ................. D-1

List of Tables
Table 1: Examples of FAA Regulatory Reviews for Existing Airport Solar Projects ...... 43
Table 2: Highest Electricity Prices in April 2010 ............................................................ 50
Table 3: Top Ten States in Solar Installations for 2009 ................................................. 53
Table 4: Examples of Ownership Structure for Existing Airport Solar Projects .............. 62
Table 5: Feasibility Checklist for Airport Sponsors ........................................................ 65

List of Figures
Figure 1: Schematic Diagram of a Typical Grid-Connected Solar PV System ................ 3
Figure 2: Typical Parabolic Trough Collector .................................................................. 6
Figure 3: Typical Power Tower Collector......................................................................... 7
Figure 4: Typical Solar Hot Water Collector .................................................................... 8
Figure 5: Typical Solar Wall Collector ............................................................................. 9
Figure 6: Example of a Roof-Mounted Solar PV System............................................... 11
Figure 7: Example of a Ground-Mounted Solar PV Installation ..................................... 12
Figure 8: Example of a Tracking Solar PV Installation .................................................. 13
Figure 9: Photovoltaic Solar Resource .......................................................................... 15
Figure 10: Schematic of the U.S. Electrical Grid System .............................................. 17
Figure 11: Schematic Flow of Electricity Transactions Over the Grid ............................ 18
Figure 12: FAA Review of Solar Projects ...................................................................... 28
Figure 13: Restricted Areas Near a Runway End .......................................................... 30
Figure 14: Physical Penetration of Airspace .................................................................. 36
Figure 15: Imaginary Surfaces that Define Navigable Airspace .................................... 38
Figure 16: Different Types of Reflection ........................................................................ 39
Figure 17: Simple Example of a Geometric Analysis .................................................... 41
Figure 18: Average On-Peak Spot Electric Prices 2009 from Regional Transmission
Organizations ................................................................................................................ 49
Figure 19: Renewable Portfolio Standards in the U.S. .................................................. 54
Figure 20: Solar Trees on Parking Garage at Boston’s Logan Airport .......................... 56

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Figure 21: Solar on New Rental Car Parking Facility at Mineta San Jose Airport ......... 58
Figure 22: Private or Third-Party Owned Business Model............................................. 60
Figure 23: Airport Owned Business Model .................................................................... 61
Figure 24: Rooftop Solar Project on San Francisco’s Terminal 3 .................................. 63

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FAA Airport Solar Guide

Preface
Over 15 airports around the country are operating solar facilities and airport interest in solar energy is
growing rapidly. In response, the Federal Aviation Administration (FAA) has prepared this report,
Technical Guidance for Evaluating Selected Solar Technologies on Airports, to meet the regulatory and
information needs of FAA personnel and airport sponsors in evaluating airport solar projects.

The guidance is intended to provide a readily usable reference for FAA technical staff who review
proposed airport solar projects and for airport sponsors that may be considering a solar installation. It
addresses a wide range of topics including solar technology, electric grid infrastructure, FAA safety
regulations, financing alternatives, and incentives.

Airport sponsors are interested in solar energy for many reasons. Solar technology has matured and is
now a reliable way to reduce airport operating costs. Environmentally, solar energy shows a commitment
to environmental stewardship, especially when the panels are visible to the traveling public. Among the
environmental benefits are cleaner air and fewer greenhouse gases that contribute to climate change.
Solar use also facilitates small business development and U.S. energy independence.

While offering benefits, solar energy introduces some new and unforeseen issues, like possible
reflectivity and communication systems interference. The guidance discusses these issues and offers new
information that can facilitate FAA project reviews, including a flow chart of FAA procedures to ensure
that proposed systems are safe and pose no risks to pilots, air traffic controllers, or airport operations.

The guidance includes case studies of operating solar projects at Denver International, Fresno Yosemite
International, Metropolitan Oakland International, Meadows Field (Bakersfield), and Albuquerque
International Sunport. Each case study highlights a particular area of interest such as the selected
technology, siting considerations, financing, and regulatory requirements.

The guidance also includes a discussion of solar financing. Most existing airport solar projects involve an
airport partnership with private investors. These arrangements take advantage of Federal and state tax
credits and state-mandated electric utility purchases of renewable energy. Sponsors benefit from these
arrangements through lower airport electric utility bills, lease revenues, and the delegation of maintenance
costs. Federal resources for airport solar development are discussed also.

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FAA Airport Solar Guide Chapter 1. Airports and Solar Energy

1 AIRPORTS AND SOLAR ENERGY: CHARTING A COURSE

Though solar energy has been evolving since the early 1990’s as a mainstream form of renewable energy
generation, the expansion in the industry over the past 10 years and corresponding decrease in prices has
only recently made it a practical consideration for airports. Solar energy presents itself as an opportunity
for FAA and airports to produce on-site electricity and to reduce long-term electricity use and energy
costs. While solar energy has many benefits, it does introduce some new and unforeseen issues, like
possible glare (also referred to as reflectivity) and communication systems interference, which have
complicated FAA review and approval of this technology. This guide discusses such issues and how
FAA reviews for solar projects can be streamlined and standardized to a greater extent.

Given the large amount of new information being created by the solar industry, a brief overview of solar
facilities is an appropriate starting point for this report, Technical Guidance for Evaluating Selected Solar
Technologies on Airports, hereafter referred to as the “Solar Guide”.

Chapter 1 provides an introduction to solar electricity and how it is delivered to customers. It includes a
description of solar photovoltaics (PV), which is one of the more practical applications for airports, other
types of solar energy systems, how systems connect and operate with the electric grid, and the specific
electricity supply and demand issues associated with solar projects at airport.

Chapter 2 reviews airport site planning issues including the life cycle of a typical solar PV project,
project participants, and airport planning considerations for locating solar facilities at airports (e.g.,
Airport Layout Plan consistency).

Chapter 3 examines the regulatory issues that FAA must consider, including Title 14 of the Code of
Regulations (CFR) Part 77 (Airspace Review) and obligations under the National Environmental Policy
Act (NEPA).

Chapter 4 describes the financial landscape for solar projects including the government incentives
available to fund projects and how the different ownership models (e.g., public vs. private) can maximize
project cost-effectiveness.

Chapter 5 reviews the Federal government’s role in solar development and includes recommendations
for future research and procedural efficiency.

Examples from existing solar projects operating at airports are presented throughout the Solar Guide to
illustrate the technical, financial, and regulatory issues of solar energy at airports in a practical manner.

1.1 Purpose of the Solar Guide

Solar is a renewable energy source that contributes to national goals of sustainability, energy
independence, and air quality improvement. It is particularly well-suited to airports because of the
available space at airports, unobstructed terrain, and energy demand. A confluence of technological
advances, public policy, and market penetration has produced a boom in the solar industry which is
intersecting with aviation interests. In a growing number of locations, solar can provide a cost-effective
and stable long-term energy supply for airports. This Solar Guide discusses the opportunities and trade-
offs of solar energy and provides the FAA with clear and consistent procedures for reviewing solar

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FAA Airport Solar Guide Chapter 1. Airports and Solar Energy

projects. It also provides the airport sponsors (referred to henceforth as “sponsors”1) and the aviation
community with a reference for technical, financial, and regulatory issues associated with solar energy.

1.1.1 What is Driving Solar Energy Development?

Governments have a strong interest in furthering the research and development of renewable energy
technologies, including solar energy. Renewable energy sources, by definition, utilize natural power
produced by atmospheric forces of the earth: sun, wind, river current, tidal current, and waves. These
energy sources require no fuel, provide continuous long-term production, and do not create emissions.
Fossil fuels (oil, gas, coal), in comparison, are finite and require combustion to release stored energy,
which produces gas emissions as a byproduct. Beyond initial developments for the military and space
programs, advances in commercial solar energy technology have been catalyzed by periodic disruption of
fossil fuel supplies and the escalation in energy prices starting in the early 1970’s. Significant
investments by government and private capital have increased exponentially since then through a
confluence of forces including awareness of climate change and concerns about national security and
energy independence. In addition, the U.S. has benefitted from investments by European nations over the
past 20 years, particularly in the areas of wind and solar, which have broadened the technology and
commercialization, resulting in higher system efficiencies and lower prices.

The types of public policy enacted by government include changes in laws, regulations, tax policies, and
agency programs. For example, the U.S. Congress approves Federal tax credits and appropriates funds
for renewable energy research and development programs administered by the Department of Energy
(DOE) and its National Laboratories and Technology Centers. Federal agencies establish policies for
leasing Federal lands for private renewable energy development. States enact laws that require electric
utilities to provide a minimum amount of production through renewable energy sources. In addition,
States offer tax credits to lure renewable energy manufacturing facilities to set up business in their State.
These credits help private renewable energy developers to either offset the initial high capital costs of
equipment or to reduce the cost of renewable electricity as it is produced. The financial implications of
government stimuli, in terms of legislative reform and in funding appropriations and tax credits, bear
significantly on the economic feasibility of solar technologies at airports and are explored in detail in
Chapter 4.

1.1.2 How is Solar Energy Impacting Airports?

Growth of the solar energy industry has led developers to approach airports with a business prospect of
locating solar facilities on airport due to the availability of cleared open space and high energy and
electricity use. More indirectly, private developers have proposed large-scale solar developments off
airport in areas utilized by aviation either near airports or along common flight paths. These interactions
have caused the aviation community to question in a broad sense whether solar energy generation is
compatible with aviation due specifically to issues such as glare, radar interference, and physical
penetration of airspace. The FAA also has had to consider whether airport solar projects it approves are
consistent with an airport sponsor’s Federal obligations regarding financial self-sustainability and
retention of airport revenue, as well as national environmental policy.

Before these specific issues can be addressed, however, it is important to discuss the basics of solar
technology and electric generation.

1
Airport “sponsors” are planning agencies, public agencies, or private airport owners/operators that have the legal
and financial ability to carry out the requirements of the Airport Improvement Program (AIP). The term is also used
in this document to refer to the Passenger Facility Charge (PFC) program, which is restricted to “public agencies.”

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FAA Airport Solar Guide Chapter 1. Airports and Solar Energy

1.2 Solar PV Basics

A solar PV system is made up of multiple components that collect the sun’s radiated energy, convert it to
electricity and transmit the electricity in a usable form. A schematic diagram of such a system is shown
in Figure 1 below.

The main component is the solar panel, which is comprised of a group of individual solar cells that
convert sunlight energy to electricity. The panels are held in place by a frame which is either fastened to
an existing structure or is placed atop a stand that is mounted on the ground. Panels are typically
comprised of 40 individual solar cells. Several panels connected together in series are identified as a
“string” and often operate as a single generating unit, meaning if one panel becomes inoperable, it shuts
down the entire string. Multiple strings assembled together into one solar facility are referred to as an
“array.”

The electricity produced by individual panels is direct current (DC) which is brought together in a
combiner box and fed as a single DC flow to an inverter. The inverter converts the electricity that is
produced by the PV cells from DC to alternating current (AC), a form that can be tapped by users of the
electrical grid (grid-connected systems are also referred to as a grid-tie system).2 Disconnects are located
in both the DC and AC lines to allow the utility company to interrupt electrical current during repair and
maintenance.3 A breaker panel is necessary for protecting the system from short circuits and voltage
surges. A utility meter accounts for the amount of electricity transfer between on-site service and the
utility grid.

Figure 1: Schematic Diagram of a Typical Grid-Connected Solar PV System

Source: Affordable Solar - http://www.affordable-solar.com/grid.tie.htm

1.2.1 Types of Solar PV Technologies

The primary types of PV technologies applicable to airports are those associated with crystalline silicon
panels. Solar cells assembled in panels are made of silicon and are the most efficient technology for

2
Standalone systems that are not grid-connected utilize a charge regulator or a controller. They also require a
battery to store electricity and make it useful during times when the sun is not shining.
3
The fire department should be consulted on disconnects to allow access to the system in the event of an emergency.

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FAA Airport Solar Guide Chapter 1. Airports and Solar Energy

converting light energy to electricity. Monocrystalline panels are made of large silicon crystals which are
less common and therefore more expensive but also operate more efficiently. Polycrystalline panels are
made of many small silicon crystals and are the most common type of solar panel. Crystalline silicon is
cut into disks, polished and connected together with metal conductors, and assembled on a panel. The
panels are covered by a thin layer of protective glass and the panel is attached to a substrate of thermally
conductive cement which traps waste heat produced by the panel and prevents it from overheating.

Other types of PV technologies include thin film and multi-junction versions. Thin-film solar is made
from amorphous silicon or other materials such as cadmium telluride. While less efficient than traditional
solar cells, thin-film can be deployed less expensively on flat building surfaces such as building rooftops
and facades to generate electricity. Multi-junction systems consist of multiple thin-film layers that
increase efficiency. Newer solar technologies are being developed using inks and dyes produced through
traditional printing techniques to decrease costs and expand deployment opportunities4.

The U.S. Department of Energy’s National Center for Photovoltaics is the central location for
research and development utilizing the expertise of the National Renewable Energy
Laboratory (NREL) and Sandia National Laboratories.

1.2.2 Energy Conversion Process and Efficiency

Photovoltaic devices convert light energy to electricity. When semiconducting materials are exposed to
light, they absorb some of the sun’s energy in the form of photons and emit electrons in the form of
electricity. However, the amount of electricity that can be generated is only a percentage of the total
amount of the sun’s energy available. Physical limitations of converting photons to electricity have been
established in the laboratory -- some photons reflect away from the panels and some pass through the
panels, so that the electricity conversion efficiency for today’s photovoltaic panels is between 6 and 20%
of the total energy available. In comparison, the burning of fossil fuels is about 28% efficient. Also, as
operating panels age and degrade, their efficiency goes down (on average about 0.5% each year).

Solar electricity performance is affected on-site by geographic, meteorological, and technical conditions.
Electricity production is dependent on the amount of solar irradiance (i.e., sunshine intensity) at any one
location, cloud cover, and other environmental factors such as smog and dust. The amount of energy
available also changes daily and seasonally depending on the position of the sun in the sky. For any
location, the maximum solar irradiance will occur at 12:00 noon on the summer solstice. Solar irradiance
is typically measured in “peak sun hours” which defines the number of hours (on average) where a
location can produce 1 kWh/m2 (kilowatt-hour per meter squared). Information on solar irradiance for
specific locations in the U.S. can be found on the NREL website.5

Panel capacity is the amount of electricity that can be generated by the panel at maximum output. The
capacity is determined by standardized testing in laboratory conditions. Solar panels vary in rated
production capacity. Denver International Airport is utilizing 216-watt panels at its Pena Boulevard
installation; Albuquerque International Sunport is utilizing 305-watt panels. The panel capacity proposed
for any new system will be determined based on many factors including available space and project
budget.

4
National Renewable Energy Research Laboratory. 2010. Solar Research. http://www.nrel.gov/solar/
5
http://www.nrel.gov/gis/solar.html

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FAA Airport Solar Guide Chapter 1. Airports and Solar Energy

Power production from a solar panel is calculated based on (1) the panel’s rated power, (2) the solar
energy availability (monthly average), and (3) efficiency loss due to elevated operating temperatures.
For example, a 315-watt panel in Phoenix Arizona in June with a 3% average efficiency loss for panel
heating would be determined as follows:

[315 watts] x [7.13 hours] x [97%] = 2.179 kWh

Regardless of panel rating, electricity production of solar panels increases as the sun rises and the panels
warm up. While one might think that maximum electricity production would occur on the summer
solstice (June 21) when the sun is highest in the sky (~12 noon), this is often not the case. Production
levels off at the ideal design temperature of 25º C (77º F) then begins to decrease as the ambient air
temperature increases. Power production decreases by 5% for every 10º C (18º F) increase over the
design temperature6.

1.3 Other Solar Power Generating Systems

Though often less suitable to airports, other types of solar power generating systems exist and are
described below.

1.3.1 Concentrated Solar

Concentrated Solar Power (CSP) systems use large reflective surfaces in massive arrays to focus the sun’s
energy on a fixed point to produce intense heat, which is then converted to electricity. The most common
means for producing electricity in these systems is to heat water and produce steam, which drives a
turbine, usually for the purpose of supplying commercial power to the grid. The two most common CSP
designs are parabolic troughs and power towers shown in Figures 2 and 3 below.

Parabolic troughs continually track the sun and concentrate the sun’s heat onto receiver tubes filled with a
heat transfer fluid. The fluid is heated up to 750º F then pumped to heat exchangers that transfer the heat
to boil water and run a conventional steam turbine producing electricity.

6
Zauscher, M. 2006. Solar Photovoltaics Panels from a Hear Transfer Perspective. Department of Mechanical and
Aerospace Engineering. University of California, San Diego.
http://courses.ucsd.edu/rherz/mae221a/reports/Zauscher_221A_F06.pdf

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FAA Airport Solar Guide Chapter 1. Airports and Solar Energy

Figure 2: Typical Parabolic Trough Collector

Whereas parabolic troughs focus sunlight to receivers located on each individual unit, power towers focus
all the facility’s sunlight to a single receiver. The power plant is comprised of individual heliostats
(mirrors) arranged in a circular array that track with the sun. Each heliostat reflects sunlight onto the
central receiver at the top of a tower. Just like the parabolic trough, a heating fluid transfers heat to create
steam to drive a turbine and produce electricity.

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FAA Airport Solar Guide Chapter 1. Airports and Solar Energy

Figure 3: Typical Power Tower Collector

One of the benefits of either form of CSP over PV is that the heated fluids can be used to store energy and
delivery electricity even when the sun is not shining.

Concentrated Solar Power projects require enhanced coordination with the FAA due to unique
issues with reflectivity, thermal plumes, radar interference, and airspace penetration.

1.3.2 Solar Thermal Hot Water

Solar thermal refers to conventional systems used to produce hot water by exposing water to the sun’s
energy either directly or by heating a fluid in a closed loop that heats the water, as illustrated in Figure 4.
The concentrated solar power systems described above are an advanced form of solar thermal employed
to produce electricity in large amounts to feed the electrical grid. Conventional solar thermal systems are
deployed as panels that contain coils filled with the heating fluid or water. These systems can be used to
serve a single household or a larger residential, commercial, or airport application. Their greatest benefit
to areas already served by the electric grid is to minimize the electricity demand on domestic or
commercial water heaters to keep water constantly hot.

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FAA Airport Solar Guide Chapter 1. Airports and Solar Energy

Figure 4: Typical Solar Hot Water Collector

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FAA Airport Solar Guide Chapter 1. Airports and Solar Energy

1.3.3 Transpired Solar Collectors

Transpired solar collectors, also referred to as “solar walls,” are placed on the sides of buildings to pre-
heat ventilation air inside the building, an illustration of which is shown in Figure 5 The design is
relatively simple: employ a heat-absorbing metal panel typically on an outer south-facing wall of a
building. Air located between the panel and the wall is heated and drawn into the building’s ventilation
system by circulating fans. Through this process, fresh air is constantly drawn into the solar heated space
and then into the building making the system particularly good for building activities that require constant
ventilation. The systems are especially effective in sunny climates with long heating seasons.

Figure 5: Typical Solar Wall Collector

1.3.4 Compatibility of Solar Generating Systems with Airports

Given the constraints of some solar energy systems, solar PV tends to be the technology that provides the
best opportunity for airports today. Based on available information, solar PV for an airport application
has the best cost-benefit ratio of the solar power alternatives. In comparison with CSP systems, solar PV
is more compatible with airport land use because it:

1. Is most cost-effective when serving a smaller on-site electricity demand as opposed to large-scale
generation for the electricity grid;

2. Has a low profile and modular design, which is compatible with low-demand airport property such
as rooftops and airfields; and

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FAA Airport Solar Guide Chapter 1. Airports and Solar Energy

3. Is designed to absorb sunlight (rather than reflect it), minimizing potential impacts of glare.
4. Doesn’t attract wildlife, which is a critical aviation hazard.

In addition, many airports are currently employing solar PV and reporting reliable and safe performance.
In contrast, CSP is typically not compatible with airports. One reason is because CSP requires more
space than is usually available on airport property. More importantly, CSP projects in general have raised
concerns about hazards to safe air navigation from:

1. Potential glare and glint caused by parabolic troughs and heliostats that might cause temporary loss
of vision to pilots on arrival or departure, or to Air Traffic Control personnel in the control tower.

2. Electromagnetic interference with on- and off-airport radar systems that may pick up a false signal
from the metal components of the mirrors with impacts that can vary based on solar tracking
activity.

3. Physical penetrations of navigable airspace from power towers that extend into Part 77 imaginary
surfaces, terminal instrument procedures (TERPS) surfaces, or the path of radio emitting
navigational aids.

4. Thermal plumes emitted by the power tower that produce unexpected upward moving air columns
into navigable air space.

Conventional solar thermal hot water units can be physically compatible with airport land uses and
activities because their design is similar to that of solar PV panels. However, solar thermal has been best
demonstrated as a supplementary source for domestic uses based on frequency of hot water use and level
of demand. Airports may want to explore the opportunity of conventional solar thermal hot water at the
same time they are looking at solar PV depending on specific hot water use conditions at the airport.

Transpired solar collectors are also potentially compatible with certain airport buildings such as hangars
or garages. These solar collectors, like conventional solar thermal hot water units, have an advantage
over PV and CSP installations in terms of local air quality because they directly offset the airport’s
consumption of conventional fuels and emissions.

All solar projects are subject to FAA review for compatibility with a safe and efficient air navigation
system. The FAA will review solar PV project to ensure that potential issues such as approach slope
penetration, reflectivity, and communication system interference are avoided. See Section 3.1 for more
information on the review process and standards.

1.4 Photovoltaic Designs for Airports

Solar PV is a technology that can readily be designed into an existing landscape without major
modifications due to its relatively simple, modular construction. For the airport environment, this means
that PV can be placed in locations that are not used for aviation activities and therefore have little value to
the airport or for alternative developments. However, because solar panels are made of expensive
materials that keep the cost of solar electricity comparatively high, it is important to minimize the amount
of engineering and construction necessary to secure the panels to keep solar electricity cost competitive.

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1.4.1 Roof-mountings
Roofs are an optimal location for solar panels because they commonly receive unobstructed sun exposure,
as seen in Figure 6. Roofs may also provide a ready-made support structure for a solar installation,
obviating the need for costly engineering and materials. Mountings will depend on the type, design, and
structural characteristics of the roof and wind-loading requirements of the panels. South facing angled
roofs require less support structure than flat roofs or those facing a direction other than south. Special
mountings will need to be considered in areas prone to hurricanes and other seasonal weather events.
Local building codes provide wind-loading design requirements. Airport buildings often have both flat
roofs (e.g., terminal buildings) requiring a generic support structure and angled roofs (e.g., hangers)
which may need little in the way of support. An analysis of the existing roof loading capacity must be
conducted to determine if structural reinforcement is required which will impact project cost. Project size
is also a cost consideration as roof-mounted systems are typically more cost-effective for “smaller”
projects whereas ground-mounted projects provide better pricing for larger projects.

Figure 6: Example of a Roof-Mounted Solar PV System

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FAA Airport Solar Guide Chapter 1. Airports and Solar Energy

1.4.2 Ground Mountings

Installation of solar panels at ground level, an example of which is seen in Figure 7, requires flat or gently
rolling terrain with unobstructed views to the south. Ground-mounted systems also require geotechnical
analysis to confirm the long-term stability of the soils that support them, particularly when deploying
tracking systems whose efficiency will decrease if the soils destabilize the panel alignment. To avoid
destabilization, ground-based panel mountings typically consist of poles and steel beams for extra
support. This increases panel-for-panel costs of ground-based systems, though economies of scale can
make larger systems more economical when space is not a limiting financial consideration. In addition,
while engineering and materials can increase costs, the technical difficulty of the engineering and
construction is typically low.

Figure 7: Example of a Ground-Mounted Solar PV Installation

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1.4.3 Tracking
Tracking systems employ hydraulic or motor driven mechanisms to move the panels such that they are
continuously perpendicular to the sun, maximizing their electric generation potential. An example of a
tracking system is seen in Figure 8. Panels can move in two directions to optimize contact with the sun.
One direction adjusts vertically to the sun’s seasonal position in the sky whereby the panel angle relative
to the ground increases or decreases. The second direction is a horizontal movement tracking the sun’s
daily path from sunrise to sunset. If the system employs one of these tracking systems it is referred to as
a “single-axis” system. If it employs both, it utilizes “dual- axis” tracking. Tracking systems introduce a
considerable amount of additional technology and complexity to solar systems, which increase capital and
maintenance costs. The efficacy of a tracking system depends on a cost-benefit comparison of the
increase in electricity production versus the increase in expense. Where maintenance issues are greater,
for example in snow or dusty conditions, financial returns decrease.

Figure 8: Example of a Tracking Solar PV Installation

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1.4.4 Remote Systems

Solar has become a preferred method to electrify many remote systems. The most visible examples are
highway signs and monitoring devices seen along roadways. The advantage of solar for these
applications is that they do not require connection to the grid. However, even with a back-up battery,
there is the potential risk that power can become interrupted.

Airports, too, have recognized the advantages of remote lighting systems. In January 2008, the FAA
issued Engineering Brief No. 76, “Using Solar Power for Airport Obstruction Lighting”7 to provide
guidance on this application. The Brief provides specific design guidance on using solar for remote
power applications, and conditions that can make them more cost-effective than connecting to the grid.
The guidance in the Brief is applicable to obstruction lights located on- and off-airport property. FAA
Advisory Circular (AC) 150-5345-50B, Specifications for Portable Runway and Taxiway Lights,
provides additional guidelines on portable airfield lighting for temporary use and solar applications which
may include solar charging of batteries. Airports with solar-powered LED obstruction lights include
Chicago O’Hare, Los Angeles International, and False River (near Baton Rouge) Louisiana.

1.5 Solar PV Supply and Demand

The feasibility of a solar PV system depends first and foremost on good solar exposure and efficient
utilization. Without those features, a solar project is unlikely to be cost-effective even with available tax
credits and other financial incentives. The basic factors that affect solar PV electricity supply and
demand are (1) the strength of the solar resource, (2) other weather factors influencing project design, and
(3) airport-specific practical considerations like amount of electricity used and available space for a
project.

1.5.1 Supply – Solar Resource and Other Weather Factors

For a site that is essentially free of shade, the amount of solar energy available for capture is dependent
upon climate and geography. The southwestern U.S. is the sunniest and driest part of the country, while
the northwest and east are cloudier and more humid. The southern U.S. also receives more solar energy
per unit area than does the north by virtue of its closer proximity to the equator.

Figure 9 illustrates the comparative solar resource across the U.S. The warm colors (reds, oranges, and
yellow) depict the areas with the strongest solar resources; the cooler colors (greens and blues) are less
desirable areas. Arizona and New Mexico comprise the majority of this optimum area. Adjacent lands
extending west to the Pacific (and Hawaii), north into Oregon and Wyoming, and east into Nebraska,
Kansas, and west Texas provide the next best tier of solar resource areas, followed by the Gulf States and
southeastern U.S. The upper Midwest, New England, and the Pacific Northwest are less optimal, while
Alaska represents the poorest resource, largely the result of its high latitude and short days.

7
FAA. 2008. Using Solar Power for Airport Obstruction Lighting.
http://www.faa.gov/airports/engineering/engineering_briefs/

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Figure 9: Photovoltaic Solar Resource

Source : http ://www.nrel.gov/gis/solar.html

Other weather factors affecting the solar resource include snow, hail, lightning, hurricanes, and dust. All
of these factors should be considered during project design and may have a modest impact on project
costs, but none is likely to represent such a severe limitation that it would prohibit proceeding with a solar
project.

Solar production benefits from the rarified atmosphere that exists at higher elevations; however a
corresponding increase in snow potential may inhibit efficiency if panels remain buried for any
substantive period of time. In such areas, some production efficiency loss should be factored into the
analysis, though elevating the panels and increasing their orientation with the ground (i.e., tilting them
appropriately) will mitigate the loss by allowing the panels to shed the snow more rapidly. In areas where
large hail storms are common, damage to the panels from falling hailstones is possible, but would be a
very site-specific consideration. However, all solar projects are designed with lightning protection to
make sure that the system is not damaged by lightning strikes. Should a site have extenuating factors,
additional protection beyond convention may be warranted. Solar projects proposed in areas of the U.S.
subject to hurricane force winds must meet enhanced building code standards to withstand hurricane-
force wind loads.

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Dust, like snow, will be a design and operations and maintenance issue. Dust that collects on the panel
surface will negatively impact the panel’s electricity production efficiency. Because many projects are
located in dry climates with little rain, owners will often conduct a panel rinse twice per year. Fixed
(non-tracking) panels will also be designed with some tilt (rather than just flat) so that when it does rain,
the water and residue slide easily from the panel rather than collecting on the panel surface.

1.5.2 Electricity Demand

The amount of electricity consumed at the airport is an important factor to consider when developing a
solar PV design concept. Solar PV works best where the electricity can be generated and consumed on-
site. This is one of the central reasons why airports are good locations for solar PV because airports are a
high energy consumption land use. A secondary factor often correlated with electricity demand is
available space.

There are economic benefits to serving an on-site electricity load with a solar project. Connecting to the
electricity grid adds costs to the project in the form of additional infrastructure and utility interconnection
fees. Solar is also physically easier to integrate into an existing land use either on rooftops or available
lands making it compatible with existing building electrical systems.

A good example of an on-site use is a rooftop PV installation on a parking garage that powers the garage
lights. A ground-mounted facility with greater generation capacity can provide electricity to a nearby
terminal or maintenance building with larger electricity consumption needs. Alternatively, a general
aviation airport with minimal electricity demand may only be able to justify a solar project if it benefits
from state electricity generation and distribution laws (See Chapter 4, Net Metering).

It is also important to note the relationship between electricity demand and property availability in
assessing the feasibility of solar projects. Urban airports, on one hand, tend to be space constrained but
have a high demand for electricity on-site. Project designers may need to first look at rooftop availability,
and secondarily creative locations on the airfield that meet FAA airport design standards. Rural airports,
on the other hand, likely have plenty of space to site a solar project, but no on-site electricity demand
requiring a grid connection and increased costs. Due to these siting and economic factors, solar projects
should be designed to balance electricity demand and available space. See Chapter 2 for more detail on
airport planning for solar projects.

1.6 The Electrical Grid

The electrical grid is a complex wired system that provides the country with access to electricity. It has
developed as a patchwork of some 4,000 separate systems, that have been consolidated into just three
primary systems -- Eastern, Western, and Texas -- each operating as a service provider. Distributed
generation facilities, like solar and wind, dispersed throughout the grid are an important new tool used by
utilities to provide electricity locally as an alternative to increasing capacity at central power plants and to
upgrading transmission lines.

1.6.1 System Infrastructure

As indicated in Figure 10 below, the electrical grid is divided up between generation, transmission, and
distribution. Power generation systems include fossil fuel plants, nuclear plants, hydroelectric dams,
biomass plants, wind farms, and solar farms. The electricity is converted by a step-up transformer to a
transmission voltage and fed out on high-voltage transmission lines that are efficient at transmitting
electricity over long distances with the least amount of electricity loss. The largest of these lines – the
backbone of the grid – have a capacity of 765 kV. As electricity is moved closer to a demand center, the

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transmission voltage is stepped-down. Very large electricity users may receive electricity at the lowest
transmission voltages of 230 or 138 kV. All other users (e.g., industrial, commercial, and residential) are
served by electricity that is further stepped-down to a distribution voltage of various capacities suited to
serve the different types of customers.

Figure 10: Schematic of the U.S. Electrical Grid System

Source: Department of Energy Office of Electricity -

http://www.oe.energy.gov/information_center/electricity101.htm

1.6.2 Electricity Transactions

Electricity commerce proceeds along two parallel systems: physical and financial. These different
transactions are illustrated in Figure 11.

Physically, electricity is produced at a generating source and pumped into the grid, from which customers
tap their own electrical needs. An independent system operator is responsible for managing the electrical
grid in a manner that ensures stability of the voltage and sufficient supply to meet the common demand.
When you turn on a light in your house, you are tapping the grid for electricity; however, the source of
that electricity may not be easy to distinguish. Physically, electricity moves through the electrical system
from source to user, where the closest users to a source are likely obtaining electricity from that source.
As users are located farther away from a generation source, it becomes more difficult to determine which
source is providing supply. In the U.S., where large regional power plants provide electricity supply as
opposed to smaller “distributed” sources, there is greater distance between the electricity generator and
the electricity consumer. However, the independent system operator is primarily focused on making sure
that the entire grid is stable and electricity is available, rather than accounting for who is using electricity
from which generator.

Financially, the utility company acts as the middle manager between electricity producers and consumers.
It buys electricity on the spot market in quantities to match the total demand of its service territory.
Market prices vary based on day and time of transaction, and are reflected in peak and non-peak prices.
The electricity a utility buys is not a specific commodity produced by a generator and delivered to the
utility; rather it is a paper transaction allowing producers to be paid for loading electricity into the grid
and customers to tap power from the grid. A comparable illustration is the electricity grid as a bathtub,
where generators fill the tub at one end and users withdraw water from various locations around the

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edges. The utility company bills customers for electricity use based on the amounts they paid on the spot
market plus their associated business fees (e.g., distribution charges, system maintenance charges, and
management fees). Many states have instituted an additional surcharge for renewable energy that has been
collected in a fund to support in-state renewable energy developments.

Utility companies also manage the local utility infrastructure in their service territory. Utilities make sure
that the electrical distribution network is functioning effectively. They also manage the infrastructure by
performing regular maintenance and constructing upgrades to ensure that future electrical demand can be
supplied.

Figure 11: Schematic Flow of Electricity Transactions Over the Grid

Another factor is that many States are passing so-called Renewable Portfolio Standards (RPS), which
require utilities to purchase a portion of their total electricity from renewable energy generators. RPS
programs create a local market for renewable energy that has a value greater than conventional energy.
To validate that the utility is “purchasing” renewable energy and that renewable energy generators are
specifically compensated for their unique commodity, paper transactions in the form of Renewable
Energy Credits (RECs) are used. Utilities pay an added price for the REC to verify their purchase of
renewable energy under the RPS mandate. That added price goes directly to the renewable energy
generator which contributes to making the generation of renewable energy profitable. In a physical sense,
the “green” electricity flows from the generator into the grid and mixes with all other electricity sources.
No user can claim to tap only “green” electricity if it is utilizing the grid8.

8
U.S. Department of Energy. 2010. Renewable Energy Certificates.
http://apps3.eere.energy.gov/greenpower/markets/certificates.shtml?page=0

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Renewable Energy Credits (RECs), like soybeans, are commodities that are bought and sold in an open
trading market. A REC represents the difference between the price of conventional electricity and the
price of the renewable electricity (also known as the price premium). Some entities, like companies
and universities, are willing to pay this premium for renewable source credits to satisfy their customers
or members. In other cases, utilities may be required by state law to buy renewable electricity and
pursue RECs, driving up their value. The extra price for RECs makes the renewable electricity product
profitable to a private developer.

1.6.3 Solar Grid-Tie System

Solar systems are often times designed to serve on-site electricity demand only. This condition may be
referred to as distributed generation. Grid-tie solar refers to those systems that feed electricity to the
utility grid. Because many airports have a substantial electricity load on-site, the electricity they generate
may never reach the grid. For others, seasonal variations in on-site demand (e.g., high load for summer
cooling, lower in winter) and electricity production (more in summer than in winter) may determine if the
airport is importing or exporting electricity from the grid.

State law determines how much the on-site generator (e.g., the airport) will be compensated for the
electricity it produces and exports. These laws are collectively termed “net metering.” States that require
utilities to compensate generators at the retail electricity price as opposed to the wholesale price provide
additional economic incentives for renewable generation. This is another important factor to consider in
evaluating project economics (see Chapter 3). Regardless of the amount of electricity produced, the
utility must approve the interconnection of the system because it will interface with the grid on-site and
therefore must meet technical specifications and provide for safety considerations.

1.6.4 Distributed Generation and Its Benefits to the Grid

Energy generation projects provide electricity to a user. Central power plants push the electricity onto the
electrical grid where it can be tapped by consumers. Smaller generation projects can be located anywhere
on the grid to serve local users. These facilities are referred to as “distributed generation” and they
include facilities like solar and wind.

Distributed generation projects benefit both the utility and the generator. By supporting a distributed
generation project, utilities can avoid more costly upgrades to grid infrastructure that may be capacity
constrained and require substantial investments. Utilities may offer their own rebate programs to
customers that make localized upgrades to minimize their electricity demand either through energy
efficiency or on-site generation. Typically, these are small investments but in some instances might be a
source for small-scale solar projects. Generators benefit by producing electricity at a cheaper cost near
the electricity users and avoiding transmission charges applied by the utility. Net metering programs
authorized by Federal legislation and incentivized by individual states require that the utility buy-back
excess electricity produced on-site.

Depending on the size of a project, locating the generation source close to the user can minimize
electricity loss (over distance) and obviate the need to compensate the local utility. These conditions are
particularly important for solar projects whose economics are tight. Building a long electrical
interconnection cable, particularly on an airport where all such lines must be buried, can be a costly
expense. This illustrates one of the fundamental advantages of rooftop solar which can be built right at
the electricity load with interconnection lines made internal to the building.

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Case Study #1 – Deploying Different PV Designs

Denver International Airport – Pena Boulevard and Fuel Farm Projects – Colorado
Denver International Airport (DIA) has been
at the forefront of airport solar energy
development projects. Currently, DIA has
constructed two projects in partnership with
private developers. The Pena Boulevard
Project, located adjacent to the entrance road
to the Jeppesen Terminal, was commissioned
in July 2008. It is a 2 MW ground-mounted
project consisting of 9,250 Sharp 216-watt
solar panels on a single axis tracking system.
A second project located at the fuel farm
went online in December 2009. That project
is a 1.6 MW ground-mounted project
consisting of 7,400 Sharp fixed solar panels.
DIA is presently exploring additional
Tracking system at the Pena Boulevard Solar Farm projects.

DIA has been first in-line, and its experiences have been very helpful to future solar projects, including its
own. One significant change between its first two projects was switching from a single axis tracking
system to a fixed system with no moving parts. Tracking is employed to maximize contact of the
photovoltaic panels with the sun and increase electricity generation efficiency. The private developer of
the first project determined that tracking was appropriate for the Pena Boulevard Project and had such a
system designed. The tracking system experienced operational difficulties exacerbated by the drastic
extremes in weather conditions which compromised the lubricating fluids. As a result, the cost of system
maintenance was higher than budgeted and downtime was necessary for repairs which reduced electricity
production. While the financial impact of these difficulties were borne by the private developer who
designed, built, and owns the facility, DIA received less solar electricity in its first year of operation than
expected. To avoid potential complications with tracking systems, the developer of the second solar
project at the fuel farm decided to deploy a fixed mounted system with no moving parts. While the fixed
system does not generate the same amount of solar electricity as a fully operational tracking system, it
provides a certain minimum electricity production level and minimizes risks associated with unexpected
maintenance costs.

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Fixed System at the Fuel Farm Solar Farm

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FAA Airport Solar Guide Chapter 2. Siting Solar Projects

2 DESIGN CONSIDERATIONS: PLANNING AND SITING

SOLAR FACILITIES
Solar PV projects are generally a compatible land use at airports because of their low profile and ease of
integration with existing facilities. The economics of projects are favorable because of the large on-site
energy demand and good solar exposure. However, projects must meets standards to protect air
navigation and existing aviation activities, as well as supporting national environmental policies.
Sponsors need to consider several factors to determine the feasibility of a solar project, including the
consistency of a project with aviation activities and approved airport master plans, potential
environmental issues associated with project siting alternatives, and the need to obtain approvals from the
FAA including an update to the Airport Layout Plan. Sponsors should consult with the FAA early and
throughout the process to ensure that a proposed project meets all FAA requirements.

This chapter starts with an overview of a typical solar project life cycle and is followed by a description
of likely project participants, airport planning design considerations, and the FAA approval process.

2.1 Solar PV Project Life Cycle

A solar system that is designed and installed properly will operate for more than 20 years. The PV panel
itself has no moving parts and can last more than 30 years9. The following is a brief description of the
stages of a solar PV project.

2.1.1 Siting and Feasibility

The siting and feasibility stage is the first step from idea to project development. Whether completed
internally by the airport, a prospective development partner, or an energy consultant, the siting and
feasibility study includes an assessment of the different locations for a project including compatibility
with aviation, central design issues such as size and architecture, and a cost/benefit analysis of alternative
scenarios. These elements are brought together to form a coherent analysis of the options with
recommendations for next steps. An important outcome of this study is to determine if the airport will
seek to own the system or lease property to a third-party private developer.

2.1.2 Design and Permitting

Once a project has been defined, it must go through a more detailed design and the permit approval
process. The airport operator or its representatives should initiate early coordination with the FAA as the
design is developed to ensure that the project complies with FAR Part 77, NEPA, and FAA requirements
for land leases and funding as applicable. Detailed design information may be needed to look at whether a
solar tracking system makes sense and to investigate issues such as roof load and geotechnical factors.
Once the design has been finalized, applications are filed for all Federal and state permit approvals.

2.1.3 Installation
Depending on project size and installation platform (building or ground), solar projects are relatively
simple to install with construction occurring in days, weeks, or months. Like any construction project,
the solar installation involves mobilization, preparation, building and connecting the system, testing, and

9
U.S. Department of Energy. 2008. Solar FAQs – Photovoltaics – The Basics.
http://apps1.eere.energy.gov/solar/cfm/faqs/third_level.cfm/name=Photovoltaics/cat=The%20Basics

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finishing. The construction manager is the critical point person to make sure all is accomplished as
designed on time and on budget. A construction safety plan must be prepared and approved prior to the
issuance of a notice to proceed.10

2.1.4 Operations and Maintenance

When the solar facility is operating, regular operations and maintenance (O&M) activity is minimal.
However, the system must be constantly monitored to ensure that its electricity production is maximized.
Should system production fall drastically, the owner will likely call in a local technical firm contracted to
perform O&M to look at the problem and make component changes as needed. This same firm may also
conduct periodic cleaning of the panels and vegetation management to ensure that the panels are
optimizing their electricity production potential. Typically, cleaning will occur twice each year and
vegetation management will depend on the setting.

2.1.5 Decommissioning/Re-commissioning
The end of a solar project’s life cycle will trigger either decommissioning (dismantling) of the system or
re-commissioning or repowering (installation of a new system). While solar panels have a manufacturer’s
expected life of 20-25 years, the industry does not have much experience with decommissioning and re-
commissioning of solar facilities because systems built more than 20-25 years ago are rare, and those
systems came with no such warranty and are quite different from the panels with warranties today. In
addition, useful life will vary among owners and will be dependent upon a particular system’s production,
an individual assessment of O&M costs, and costs and benefits of repowering the system. As an
example, a system constructed on a school in Massachusetts is still producing about 90% of its original
design output 29 years after being installed.

2.2 Project Participants

The following is a brief description of each of the participants in a solar project. Generally, these
participants are the same regardless of owner or business structure. However, their level of involvement
may differ given the business structure and project details.

2.2.1 FAA Airports

There are 9 FAA Regions and 21 FAA Airport District Offices (ADOs) that manage the FAA’s day-to-
day operations with the nation’s airports. These operations include airport safety and standards, grant
management, and compliance. Regional FAA and ADO engineering, planning, compliance, and
environmental specialists are responsible for reviewing proposed airport projects and determining if they
comply with Federal airspace, airport, and environmental regulations, as well as airport sponsor’s
obligations under Federal grant agreements and surplus property deeds of conveyance.

The FAA Office of Airports in Washington DC (Headquarters) develops national policies, standards,
regulations, and guidance for the national system of airports and oversees Federal funding, compliance,
and airport environmental reviews. Generally, solar projects are reviewed at the regional level with
Headquarters becoming involved only if a project requires additional resources or presents a complex
problem. Indeed, this guidance is intended to clarify FAA policy on solar projects in order to support
regional decision-making.

10FAA Order 5100.38C (Airport Improvement Program) states: All Safety Phasing Plans must be received, reviewed, and
coordinated with other FAA operating administrations, approved for airspace review, and approved for use prior to the start of all
construction projects.

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FAA Airport Solar Guide Chapter 2. Siting Solar Projects

The FAA role in solar energy is multi-faceted.

First, the FAA ensures that solar projects are sited Early coordination with the FAA on solar
properly and do not cause safety problems for projects is essential to obtain FAA input and to
aviation or otherwise interfere with aeronautical address all of the issues so that timely approvals
and airport activities. Regional personnel are possible.
coordinate the airspace reviews of all construction
projects with other FAA organizations, including the Air Traffic Office of Obstruction Evaluation. FAA
also reviews solar project agreements for consistency with an airport sponsor’s Federal obligations for its
financial self-sustainability, its preservation of legal rights and powers, and its retention of airport
revenue. In addition, the FAA is an operator of solar technology, generally PV solar, in remote areas or at
facilities where the construction of electrical lines is more expensive (e.g., LED runway lights, remote
communications, etc.). And finally, the FAA provides information and, in limited circumstances, funding
incentives to sponsors for solar installations. In this regard, the FAA seeks to support the modernization
and improved efficiency that solar technology can provide to airports.

2.2.2 Airport Sponsor

The airport sponsor, whether the owner or just the host of a solar facility, must act as the project’s lead
applicant and main contact with the FAA. This responsibility extends to projects where a private solar
developer is leasing land from the airport to construct, own, and/or operate the facility. In this case, all
private entities involved in the project must be named on the required applications and forms. The
sponsor must be familiar with the regulatory review process and communicate on a regular basis with the
FAA to ensure that adequate information is developed for the project and that the approval process is
proceeding correctly. For solar projects on-airport, the airport sponsor is generally the applicant for all
permits and approvals. For off-airport projects, the developer will be the sole applicant.

The sponsor will be the day-to-day “eyes and ears" over the facility but will rely on other technical
experts for installation, operations, and maintenance. The airport will use the electricity produced and
either deduct that use from its regular utility bill (and realize cost savings) or pay the private owner a set
price for the electricity. The facility owner must work with the utility company (and installer) to ensure
that the facility is designed and built to conform to the electrical grid. Regardless of ownership structure,
the airport also coordinates with the FAA regional office on siting, design, and procurement to ensure that
the facility conforms to FAA regulatory and funding standards.

Prior to submitting any applications for FAA approval, the sponsor should contact the regional airport
planning staff to discuss the components of a proposed project. Using this Guide, the region or ADO and
the airport can consider the issues associated with locating solar projects on airports and draw on
expertise acquired by the sponsor to assess the potential for a project.

2.2.3 Utility
Regardless of whether the utility is a private investor-owned utility or a division of municipal or state
government (or quasi-public authority), the primary role of the utility is as protector of the electrical grid.
It must ensure that any generation system with a connection to the electric grid will not negatively impact
the grid. It must also ensure that it can access the system and shut it down for emergency operations and
scheduled system maintenance and repairs. The utility is also responsible for understanding the impact of
renewable energy systems on their state regulatory mandates and on company/agency revenue. Many
states have enacted renewable energy standards, which require utilities to generate or purchase a specified
amount of renewable energy per year. When purchasing renewable energy, utilities can accomplish their
mandates by acquiring renewable energy credits from eligible electricity producers. In addition, utilities

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FAA Airport Solar Guide Chapter 2. Siting Solar Projects

also need to be aware of when distributed energy projects go on-line so that they can forecast drops in
demand for grid-produced electricity and potential impacts on company revenue.

2.2.4 Private Developer

Private developers may act as a party contracted by the airport operator to build a solar facility, or they
may act as a turn-key contractor to design, finance, build, own, and operate a facility that supplies
electricity to the airport as a customer. In either case, the private developer brings to the airport a central
contact for the technical and financial aspects of solar development. Airports may seek to hire their own
experts as a check on the information provided by the developer.

2.2.5 Installer
The installer is the company with experience designing and installing solar systems. The developer may
also be the installer or the installer may be contracted to design and build the system.

2.2.6 Financier
Financiers can take a variety of forms depending on the business structure and ownership. Banks may
provide financing regardless of ownership. Private investors can take a diversity of forms but could
include individuals, companies, money fund managers, and venture capitalists. If the airport looks to
raise its own funds from borrowing, it may due so through municipal bonds or a project-specific
fee/charge/tax. Airports may also obtain funding through enterprise accounts, funding from other
municipal entities (like the municipal utility), and from grants. Private entities will take advantage of tax
credits from the Federal government (through the Internal Revenue Service) and from state taxes where
tax incentive programs have been enacted. Private entities can also use the power purchase agreement
(contract between the Airport and Developer for long-term electricity purchase), net-metering revenue,
and value of renewable energy credits to help secure bank and private investor financing. All of these
factors are discussed in greater detail in Chapter 4.

2.2.7 Other
Other entities that might be involved in an airport solar project include state and municipal governments,
interest groups, communities, and individuals. Government entities will provide supporting and
coordination roles to the airport. For example, fire departments may need to disconnect system
infrastructure in the event of an emergency. Local groups may offer technical assistance for development
of projects and community groups may want to know about the airport’s solar activities and how they
benefit or potentially impact the community.

2.3 Airport Land Use and Safety Planning

Every airport sponsor has accepted an obligation to protect the airport from incompatible land uses. As
such, the airport owner must take care to know of potential land uses near the airport that may impact
aviation or expose the airport to liability. At the very least, sponsors that have legal or proprietary control
of land near its airport (cities and counties, for example) must prevent uses that are incompatible with
aeronautical uses of the airport, even if these uses are beneficial to the sponsor for non-aeronautical
reasons. Failure to take prudent steps and to exercise appropriate rights and powers to preserve the
aeronautical utility of the airport may lead to a loss of future Federal funding. In many cases, a sponsor
may not have the authority to prevent incompatible land uses near the airport. In such cases, the sponsor
should raise its concerns during public hearings and comment periods associated with project approvals.

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FAA Airport Solar Guide Chapter 2. Siting Solar Projects

Active project planning starts with a review of airport land use and safety criteria and approvals. Figure
12 below presents a flow chart of the FAA’s review process for solar projects. The following section
addresses airport land uses and safety factors that must be considered prior to proceeding with airspace
and environmental reviews.

2.3.1 Lands and Buildings

In the process of exploring the technical viability of solar generation, the next stage is to evaluate the
specific aspects of project siting on the airport. One important consideration is available space. Many
airports have large open areas that may remain unused unless converted to an application like solar.
Available spaces might include noise buffers, flat areas near runways where other uses would infringe on
14 CFR Part 77 surfaces, or tops of hangars (though concerns for reflectivity and safety could still limit
the application of solar energy systems in some of these spaces). Because land-constrained urban airports
have fewer siting options than airports in more rural settings, rooftop installations on terminals, hangers,
and parking garages can sometimes be their only practical option. The FAA requirement that the airport
sponsor secure fair rental value from non-aeronautical lessees could impact the financial structure of a
solar proposal at a land constrained airport.

Ground-mounted solar projects have been successful at airports where the airport sponsor either (1) has
land that can be used for solar without affecting aeronautical planning or competition with other potential
uses, or (2) has identified unique compatible airport parcels to safely site solar on land that serves an
aeronautical purpose but may not be used for more intensive development. Ground-mounted projects are
only cost-effective when built at a larger scale occupying an area of multiple acres too large to be sited on
rooftops. Larger projects can offset the added cost of mounting structures by providing more electricity
revenue (or savings) relative to fixed costs of equipment and land prices.

Roof-mounted solar projects are constrained in size by available roof space. They are particularly
suitable at airports that either (1) do not have a large on-site electricity demand, or (2) have little open
land available for the safe placement of a ground-mounted system. Because roof-mounted projects are
collocated with a building electrical system, the cost of infrastructure from the panels to the existing
network tends to be smaller.

Under either option, the project must evaluate existing aviation and airport activities and ensure that the
project will not have a negative effect.

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FAA Solar Guide Chapter 2. Siting Solar Projects
Figure 12: FAA Review of Solar Projects
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 FAA Airport Solar Guide Chapter 2. Siting Solar Projects

2.3.2 Airport Design Standards

The design of airports and their facilities is strictly regulated to ensure that airports operate in a safe and
efficient manner. Airport design guidelines are provided in FAA Advisory Circular (AC) 150/5300-13,
Airport Design11. Some of the relevant zones near runways and taxiways where placement of structures
and activities are restricted include:

Building Restriction Line: a line that identifies suitable building area locations on airports. The
BRL should encompass runway protection zones, runway object free areas, the runway visibility
zone, NAVAID critical areas, areas required for terminal instrument procedures, and airport
traffic control tower line of sight.

Clearway: area connected to and extending beyond the runway ends. It has a slope from the
runway end of not greater than 1.25 percent and extends from 500 to 1,000 feet from the runway
end.

Object Free Area: an area that must be free of objects except those necessary for air navigation
or ground maneuvering purposes (see Figure 12).

Obstacle Free Zone: an area adjacent to the runway that precludes taxiing or parked airplanes,
and obstacle penetrations except for frangible visual NAVAIDs.

Runway Protection Zone (RPZ): an area off the runway end to enhance the protection of people
and property on the ground. While it is desirable to keep all objects clear in the RPZ, some
objects are permitted as long as they do not attract wildlife, are outside the OFA, and do not
interfere with navigational aids. For example, automobile parking facilities, although
discouraged, may be permitted. Residences and places of assembly are prohibited from the RPZ
(see Figure 12).

Runway Safety Area (RSA): a defined surface surrounding the runway prepared to reduce the
damage to aircraft that overshoot/undershoot the runway. No objects can be sited in an RSA
unless they are required to be there because of their function.

Taxiway Safety Area: a defined surface alongside the taxiway prepared to reduce damage to
aircraft. No objects can be sited unless they are necessary because of their function.

Taxiway Object Free Area: are areas adjacent to taxiways that prohibit service vehicle roads,
parked airplanes, and above ground objects except those located in the OFA because they are
needed for air navigation and ground maneuvering.

The FAA has broad authority to approve the placement of specific structures and activities relative to
their potential impact on aviation. Sponsors should review the FAA’s Airport Design AC guidelines
when evaluating siting. Sponsors should also be aware of specific locations that may comply in principal
with the design AC but may be subject to discretionary FAA review for potential issues such as glare.

11
FAA. 1989. Airport Design. FAA Advisory Circular 150/5300-13. Most recently amended in 2009;
http://www.faa.gov/airports/resources/advisory_circulars/index.cfm/go/document.current/documentNumber/150_53
00-13

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 FAA Airport Solar Guide Chapter 2. Siting Solar Projects

Figure 13: Restricted Areas Near a Runway End

Source: Advisory Circular 150/5300-13, Airport Design

In general, the FAA does not recommend that sponsors locate solar facilities in the RPZ. However, the
FAA will consult on specific proposals like the one presented by Fresno on a case-by-case basis (see Case
Study #2, Solar Project Siting at Fresno Yosemite International Airport). Working with the FAA in
advance of site selection to confirm the appropriate siting relative to any discretionary criteria is
important whether conducted as part of a larger master planning process or as a stand-alone project.

2.3.3 Consistency with Aviation and Airport Activities

Airports have a primary mission to serve the flying public and facilitate safe and convenient air travel.
All other activities occurring at airports must support this primary mission and therefore must be
consistent with those fundamental activities.

In assuring compatibility, airport sponsors should use guidance provided in the Airport Design AC
(150/5300-13) when siting PV installations and work with the FAA, State Aeronautics Divisions, and
stakeholders on master planning activities. While the Airport Design AC provides clear information
about areas critical to the protection of people and property, other planning activities like those associated
with solar facilities are discretionary. Working through the issues to understand the basic implications of
siting decisions will require information gathering, consultation, and education. In determining whether a
proposed solar project is compatible with aeronautical activities, sponsors should consider the following.

1. The project cannot be located in a Runway Object Free Area, Obstacle Free Zone, Runway Safety
Area, Taxiway Object Free Area or a Taxiway Safety Area.

2. The project cannot penetrate imaginary surfaces that define the lower limits of airspace including
the clearway.

3. The project must demonstrate that glare will not impact airspace safety. (Recommendations for
meeting this standard are described in Section 3.1.2.)

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4. The project must consider construction period impacts on aviation. Airside projects may result in
modifications to typical flight procedures if contractors and equipment produce a temporary
impact on airspace. This may result from the need to access the project site by passing vehicles
and equipment close to runways. It may also occur if a large crane is necessary for installation
and the crane penetrates airspace due to its height.

5. The project must use airport property that is not designated for aeronautical activities or request a
formal land release or change in land use.

The evaluation of a project’s consistency with aviation and airport activities is best conducted in
partnership with the FAA, using the Airport Layout Plan (ALP) as a starting point. Once the
compatibility assessment steps listed above have been taken, the sponsor will need to file a Form 7460
and obtain a formal airspace review from the FAA (see Section 3.1).

2.3.4 Consistency with the Master Plan and Airport Layout Plan
The FAA works with airports on a variety of planning processes. Those most relevant to solar projects
are Airport Master Plans and ALPs.

An Airport Master Plan is a comprehensive study of an airport which describes the short-, medium-, and
long-term development plans to meet future aviation demand. In accordance with AC 150/5070-6B,
Airport Master Plans 12, Master Plans are developed through a collaborative process to engage the airport,
agencies, businesses, and stakeholders in planning for the airport’s future. The purpose of the Master
Plan is to identify critical issues related to the airport’s infrastructure and direct financial resources to
address those issues. The ALP is then modified to include future infrastructure improvement projects
identified in the Master Plan.

Airports are beginning to recognize the potential for solar and may wish to identify possible future project
locations in the Master Plan and potentially the ALP. Most airports today have not included solar
projects as part of their future planning because the opportunity to develop on-site solar has only recently
become economical and foreseeable. Oftentimes, airports respond to an immediate opportunity presented
by a private party to partner on a solar project without extensive forecasting or planning. Referring to the
ALP is critical for both aviation compatibility and future success of solar generation. Airport sponsors
should review the ALP to determine if future projects are planned that might interfere with solar access.

As specified in AC 150/5070-6B, an ALP depicts both existing and planned land uses and facilities at an
airport. Projects proposed for FAA funding must be identified on the ALP. To fulfill this requirement,
the ALP typically needs to depict the features of the existing and planned built environment on the
airport. For example, the built environment typically shown on the ALP includes the outline of a building
footprint or the limits of pavement. Facilities collocated with existing structures, such as an elevator shaft
on the roof of a terminal building, are usually not depicted on the ALP as they are located within the
footprint of the collocated structure. Without changing the footprint outline of the structure, the collocated
facility does not constitute a change to the ALP and subsequently a Federal action. While the need for
plan updates will vary depending on the number and type of projects completed by airports, the airport is
required to update the ALP if one has not been completed in several years. Grant assurances state that the
sponsor must maintain an up-to-date ALP. In general, solar installations at airports are either collocated
with existing facilities or installed independently on the ground.

12
FAA Advisory Circular AC 150/5070-6B, Airport Master Plans, May 01, 2007
http://www.faa.gov/airports/resources/advisory_circulars/index.cfm/go/document.current/documentNumber/150_50
70-6

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2.3.5 Airport Layout Plan Approval

The ALP must be approved by the FAA prior to authorization of Federal funds for airport improvement
projects. The importance of the ALP is as a consensus document illustrating existing conditions and
future development plans at the airport. Some small-scale development activities may not be specified on
the ALP. However, it is important to distinguish areas available for future aviation and non-aviation
purposes in lieu of specific development projects.

Solar projects have typically not been depicted on the ALP prior to project approval by FAA due to the
relatively quick planning and construction period. With the broader recognition that solar generation
might become part of an airport’s development plans, sponsors are advised to include solar projects on
ALPs currently under revision or update. Ground-mounted solar projects trigger a Federal action and are
subject to NEPA review, which must be completed prior to construction.

As part of this Guide, the FAA is providing recommendations on what types of solar projects should be
depicted on an ALP. In summary, solar installations of any size, located on the airport, that are not
collocated on an existing structure (i.e., roof of an existing building) and require a new footprint, need to
be shown on an Airport Layout Plan (ALP). Collocated solar installations need to be shown on the ALP
only if these installations substantially change the footprint of the collocated building or structure.
Sponsors need to revise the top elevation of buildings or structures on the ALP when solar installations
increase the building or structure height.

2.3.6 Land Release Approval

Land releases are often necessary for solar projects where land is leased to a private entity for a 15-25
year period to own and operate a solar facility.13 Several airports have developed solar facilities through a
public-private partnership whereby land is leased to a private developer who owns and operates the
facility and provides the electricity to the airport. In order for the sponsor to lease land for a non-
aeronautical purpose (such as electricity generation), it must consult with FAA. Solar projects in
Bakersfield, Denver, Fresno, and Oakland where land was leased for the solar facility, followed the
procedures summarized below.

Airport property is dedicated for airport purposes, including non-aeronautical, but aviation-compatible
uses to generate airport revenue. As airport property, however, there are certain obligations covering the
use of this property, which must be addressed before the land can be used or disposed of for non-
aeronautical uses. The FAA must ensure solar power use agreements for airport property for sale or lease
demonstrate that such use provides prudent financial benefit to the airport.

In some cases, extensive solar power uses of airport property will require FAA approval of a land release
request. If so, the sponsor must submit documentation which describes, among other items, the airport’s
obligations to the land based on how it was acquired, the type of land release request, justification for the
release, demonstration that the airport will obtain fair market value in return for the release, and what will
be done with the revenue that is generated by the release. The proposed action subsequent to the release
must be shown to be in compliance with the ALP.

In most cases, the FAA prefers that airport land not needed for aeronautical use be leased rather than sold
so that it provides continuous income for airport purposes and preserves the property for future aviation
usage so long as the future use is compatible with airport operations. Solar projects where land is leased
to a private developer for a 15-25 year period provides the airport with the right to reclaim the property

13
http://www.faa.gov/airports/eastern/aip/sponsor_guide/media/SGSect3.doc

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for future use after the lease period has ended. Land acquired with AIP noise compatibility grant funds
must, generally, be sold after the airport sponsor converts the land to compatible uses.

The sponsor must submit to the ADO the request to change the ALP and update Exhibit A to show that
the property will be used for non-aeronautical purposes. As stated in Section 4.2.2, the FAA’s approval
either to release property for use as a solar electricity facility or to concur with an appropriate lease of
suitable airport property may constitute a Federal action triggering a NEPA review which must be
completed prior to FAA issuing a land release.

2.3.7 Environmental Screening

In addition to its statutory responsibility to protect air navigation and facilitate efficient air travel, which
are accomplished in part through effective airport planning and design, the FAA must also ensure that
approved projects and funds are consistent with national environmental laws and policies. Many solar
projects may be subject to review under the NEPA, as well as be required to obtain environmental permits
from Federal, state, and local agencies. Therefore, it is important that project proponents conduct an
initial environmental screening of their project to identify as potential environmental fatal flaws early on
before the project proceeds too far into siting and design.

Environmental issues that might arise in the NEPA review and individual permit review include
endangered species, wetland disturbance, water quality degradation from erosion and sedimentation,
hazardous materials, and historic and archaeological resource impacts. While existing solar facilities on
airport property do not appear to be wildlife attractants, the environmental screening process should look
carefully at potential wildlife impacts.14 The environmental screening process should collect information
on existing and historic habitats and land uses in the proposed construction area using such means as
statewide geographic information system databases, file searchers, and consultation with municipal
planners and agency personnel. Should a unique environmental resource be identified for a proposed site,
alternative sites or mitigation of adverse impact options should be evaluated before proceeding (see
Section 3.2 for discussion of the environmental review process).

14
Example: the County of Sacramento CA is addressing concerns about the potential impacts of proposed airport
solar development on hawk foraging habitat (Letter from the Airport Manager to the County Planning and
Community Development Department, September 29, 2010).

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 FAA Airport Solar Guide Chapter 2. Siting Solar Projects

Case Study #2 – A Unique Siting Example

Fresno Yosemite International Airport (FYI) – California

Source: City of Fresno

The City of Fresno constructed a 2.4 MW ground-mounted solar generation system in June 2008. The
project consists of 11,700 Sharp solar panels on a single axis tracking system. The project was financed
through a Power Purchase Agreement (PPA) with a private developer, and received state support in the
form of rebates and utility long-term contract purchase requirements. The panels produce enough
electricity to serve approximately 58% of the airport’s annual average electricity load.

The airport discussed several different sites with the private developer and ultimately agreed to locate the
project near the end of Runway 29 and adjacent to the Object Free Area but inside a portion of the
Runway Protection Zone. This area, due to its location relative to air traffic, was unusable for any land
uses requiring regular presence by people. In addition, unmanned structures were constrained to only low
profile ones that did not penetrate into the approach zone. For those reasons, the land had little value
which made it a very suitable location for a solar project.

Because leases must be reviewed by the FAA and the price of the lease must reflect a fair market value
standard, leases of land potentially valuable for other development results in higher solar electricity
prices. Locating solar on land with less value keeps the solar electricity price down making PPA prices
both cost competitive for the airports and profitable for the private developer. As a result, land that would
otherwise provide no value becomes a new revenue source to the airport. In general, the FAA does not
recommend that airports locate solar projects in the RPZ. However, the FAA will review specific airport
proposals like the one presented by Fresno on a case-by-case basis.

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 FAA Airport Solar Guide Chapter 3. Regulatory and Safety

3 REGULATORY AND SAFETY REQUIREMENTS FOR SOLAR

PROJECTS: MEETING AIRPSACE AND ENVIRONMENTAL
STANDARDS

Solar development proponents must plan their projects to avoid impacts on aviation and the environment.
As part of an Airspace Review, Airport Sponsors should assess airspace penetration, reflectivity, and
communication systems interference for all airport solar projects whether ground or building-mounted.
The FAA is also authorized to review all projects for compliance with national environmental laws. This
chapter provides guidance to the FAA and sponsors on FAA procedures for reviewing proposals to
construct solar PV projects on airport property or in the vicinity of the airport. Because solar projects
have opened up new issues that are not familiar to FAA technical reviewers and sponsors, past FAA
project reviews were performed on a case-by-case basis. This chapter provides FAA regional personnel
with needed information and tools to conduct more consistent and timely reviews of solar projects.
Please refer back to Figure 12, FAA Review of Solar Projects.

The following section summarizes FAA Airspace Reviews under Part 77, which provides the FAA with
broad authority for protecting the nation’s airspace. The discussion of Part 77 requirements includes the
triggers for FAA review of solar projects at or in the vicinity of the airport.

3.1 Airspace Review

The FAA’s foremost mission is to ensure a safe national air navigation system. To meet this objective, the
FAA conducts aeronautical studies of proposed activities that could impact airspace. These studies
review physical incursions of proposed structures into airspace, interference with radar communications,
and any other conditions that might negatively impact air traffic. Figure 14 illustrates potential airspace
conflicts. Due to its broad authority to protect airspace, the FAA must be given data to review any
construction or alteration on a public use airport regardless of height or location. For projects
proposed on airport property, sponsors must file documentation with the FAA so that it can complete an
airspace review and assess the potential impact of the project on air navigation. For off-airport projects,
local governments, solar developers, and other stakeholders in the vicinity of an airport have the
responsibility to inform the FAA about proposed projects so that the agency can determine if the project,
especially if large, presents any safety or navigational problems.

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Figure 14: Physical Penetration of Airspace

All solar projects at airports must submit to FAA a Notice of Proposed Construction Form 7460 under
Part 77 to ensure the project does not penetrate the imaginary surfaces around the airport or cause radar
interference.15 Even if a project will be roof mounted and the height will be below an existing structure
such as a building or light fixture, the sponsor must still submit a case for analysis to ensure that the
project does not cause glare or interfere with radar installations.16 The FAA will conduct an aeronautical
study of the project and will issue a determination of hazard or no hazard. The timeline for these
approvals is typically 30-45 days.

Due to its broad authority to protect aviation safety, the FAA may need to review any major solar
project regardless of height or location.

FAA’s regional or ADO offices will process the 7460 data and conduct the aeronautical studies to ensure
the project will not penetrate the imaginary surfaces or interfere with radar. The aeronautical studies will
be conducted by the following offices:

 Air Traffic Obstruction Evaluation Office (AT OES) – Responsible for evaluating Part 77
requirements.

 Air Traffic Operation Service Group (AT OSG) – Responsible for coordinating with air traffic
control to identify any operation impacts.

15
FAA authority to review non-physical penetrating impacts such as communications interference and reflectivity is
stated in Section 6.3.2 of “Procedures for Handling Airspace Matters”, FAA Order JO 7400.2G, April 10, 2008.
16
The 7460 case data can be completed as a hard copy or online at the Obstruction Evaluation / Airport Airspace
Analysis (OE/AAA) website - https://oeaaa.faa.gov/oeaaa/external/portal.jsp.

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 Technical Operations (Tech Ops) – Responsible for evaluating the case for impacts to NAVAIDs,
conducting electromagnetic and line-of-sight shadow studies, and highlighting frequency
problems.

 Flight Standards (FS) Responsible for reviewing proposals to determine the safety of aeronautical
operations, and of persons and property on the ground.

 Flight Procedures (FP) - Responsible for evaluating proposals to determine impacts on instrument
procedures and whether aircraft instrument operations can be conducted safely.

 Airports (ARP) – Identify the structure’s effect on existing airports and planned improvements
based on airport design criteria including assessing potential impacts on airport operations,
capacity, efficiency, and development, and making recommendations for eliminating adverse
effect.

The Form 7460 should be accompanied by a discussion of consistency with the ALP, and address
airspace issues of physical penetration, communications and systems interference. It should include the
following information:

 Location of panels

 Location of radar facilities

 Location of Control Tower

 Verification that panels are located outside of airport design prohibited areas

 Verification that panels will not physical penetrate airport imaginary surfaces

 Verification that solar facilities will not block radar communications

Once the FAA completes the aeronautical study, a determination will be made regarding the impact to air
navigation. The determination will be one of the following: a No Hazard Determination, a Conditional
Hazard Determination, or a Final Hazard Determination. Airport sponsors for currently operating solar
PV projects that have submitted Form 7460 to the FAA for an airspace review have obtained a “No
Hazard Determination.”

3.1.1 Airspace Penetration

14 CFR Part 77 imaginary surfaces establish standards for determining obstructions in navigable airspace.
These imaginary surfaces extend out from the runway in a manner that reflects where aircraft are likely to
fly while also accommodating unforeseen aircraft maneuvers. The height above the ground of the
imaginary surface is lowest near the runway and increases at distance from the runway. Away from
airports, airspace begins at 200 feet above ground level.

Airports must maintain vegetation, prevent building, and manage any temporary construction activity to
conform with Part 77 analysis determinations. A figure depicting the imaginary surfaces extending out
from the airport is presented below.

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 FAA Airport Solar Guide Chapter 3. Regulatory and Safety

Figure 15: Imaginary Surfaces that Define Navigable Airspace

Large structures, like communication towers and wind turbines, often exceed 200 feet in height and
therefore are required to submit a Form 7460, Notice of Proposed Construction or Alteration. Structures
shorter than 200 feet but located within 20,000 feet of a runway may also penetrate navigable airspace.
Solar panels, when tilted properly to the south-facing sun, extend to a height of as little as three feet above
the ground making it possible for siting close to runways without penetrating an imaginary surface. The
low profile of solar panels allows for greater flexibility in finding the most appropriate location on the
airport for electricity generation. Projects that have located solar panels in close proximity to runways
and taxiways have conducted analyses to ensure that the solar panels do not penetrate the imaginary
surface.

3.1.2 Reflectivity
Reflectivity refers to light that is reflected off surfaces. The potential effects of reflectivity are glint (a
momentary flash of bright light) and glare (a continuous source of bright light). These two effects are
referred to hereinafter as “glare,” which can cause a brief loss of vision, also known as flash blindness.
FAA Order 7400.2, Procedures for Handling Airspace Matters, defines flash blindness as “generally, a
temporary visual interference effect that persists after the source of illumination has ceased.”
The amount of light reflected off a solar panel surface depends on the amount of sunlight hitting the
surface, its surface reflectivity, geographic location, time of year, cloud cover, and solar panel orientation.
As illustrated on Figure 16, flat, smooth surfaces reflect a more concentrated amount of sunlight back to

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 FAA Airport Solar Guide Chapter 3. Regulatory and Safety

the receiver, which is referred to as specular reflection. The more a surface is polished, the more it
shines. Rough or uneven surfaces reflect light in a diffused or scattered manner and, therefore, the light
will not be received as bright.
CSP systems use mirrors to maximize reflection and focus the reflected sunlight and associated heat on a
design point to produce steam, which generates electricity. About 90 percent of sunlight is reflected.
However, because the reflected sunlight is controlled and focused on the heat collecting element (HCE) of
the system, it generally does not reflect back to other sensitive receptors. Another source of reflection in
a CSP system is the light that contacts the back of the HCE and never reaches the mirror. Parts of the
metal frame can also reflect sunlight. In central receiver (or power tower) applications, the receiver can
receive concentrated sunlight that is up to a thousand times the sun’s normal irradiance. Reflections from
a central receiver, although approximately 90% absorptive, can still reflect a great deal of sunlight.
Solar PV and SHW panels are constructed of dark, light-absorbing materials and covered with an anti-
reflective coating designed to maximize absorption and minimize reflection. However, the glass surfaces
of solar PV and SHW systems also reflect sunlight to varying degrees throughout the day and year. The
amount of reflected sunlight is based on the incidence angle of the sun relative to the light-sensitive
receptor (e.g., a pilot or air traffic tower controller). The amount of reflection increases with lower
incidence angles. In some situations, 100% of the sun’s energy can be reflected from solar PV and SHW
panels.

Because solar energy systems introduce new visual surfaces to an airport setting where reflectivity could
result in glare that can cause flash blindness to those that require clear, unobstructed vision, project
proponents should evaluate reflectivity during project siting and design.

Figure 16: Different Types of Reflection

Completing an Individual Glare Analysis

Evaluating glare for a specific project should be an iterative process that looks at one or more of
the methodologies described below. Airport sponsors should coordinate closely with the FAA’s
Office of Airports to evaluate the potential for glint and glare for solar projects on airport
property. These data should include a review of existing airport conditions and a comparison
with existing sources of glare, as well as related information obtained from other airports with
experience operating solar projects.

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Because the FAA has no specific standards for airport solar facilities and potential glare, the type
of glare analysis may vary. Depending on site specifics (e.g., existing land uses, location and
size of the project) an acceptable evaluation could involve one or more of the following levels of
assessment:

(1) A qualitative analysis of potential impact in consultation with the Air Traffic Control
Tower, pilots, and airport officials
(2) A demonstration field test with solar panels at the proposed site in coordination with
Air Traffic Control Tower personnel
(3) A geometric analysis to determine days and times when there may be an ocular
impact.

The FAA should be consulted after completing each of the following steps to determine if potential
reflectivity issues have been adequately considered and addressed.

The extent of reflectivity analysis required to assess potential impacts will depend on the specific
project site and system design.

1. Assessing Baseline Reflectivity Conditions

Reflection in the form of glare is present in current aviation operations. The existing sources of glare
come from glass windows, auto surface parking, rooftops, and water bodies. At airports, existing
reflecting surfaces may include hangar roofs, surface parking, and glassy office buildings. To minimize
unexpected glare, windows of air traffic control towers and airplane cockpits are coated with anti-
reflective glazing. Operators also wear polarized eye wear. Potential glare from solar panels should be
viewed in this context. Any airport considering a solar PV project should first review existing sources of
glare at the airport and the effectiveness of measures used to mitigate that glare.

2. Tests in the Field

Potential glare from solar panels can easily be viewed at the airport through a field test. A few airports
have coordinated these tests with FAA Air Traffic Controllers to assess the significance of glare impacts.
To conduct such a test, a sponsor can take a solar panel out to proposed location of the solar project, and
tilt the panel in different directions to evaluate the potential for glare onto the air traffic control tower.
For the two known cases where a field test was conducted, tower personnel determined the glare was not
significant. If there is a significant glare impact, the project can be modified by ensuring panels are not
directed in that direction.

3. Geometric Analysis

Geometric studies are the most technical approach for reflectivity issues. They are conducted when glare
is difficult to assess through other methods. Studies of glare can employ geometry and the known path of
the sun to predict when sunlight will reflect off of a fixed surface (like a solar panel) and contact a fixed
receptor (e.g., control tower). At any given site, the sun moves across the sky every day and its path in
the sky changes throughout year. This in turn alters the destination of the resultant reflections since the
angle of reflection for the solar panels will be the same as the angle at which the sun hits the panels. The
larger the reflective surface, the greater the likelihood of glare impacts. Figure 17 provides an example of
such a geometric analysis.

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 FAA Airport Solar Guide Chapter 3. Regulatory and Safety

Figure 17: Simple Example of a Geometric Analysis

Facilities placed in remote locations, like the desert, will be far from receptors and therefore potential
impacts are limited to passing aircraft. Because the intensity of the light reflected from the solar panel
decreases with increasing distance, an appropriate question is how far you need to be from a solar
reflected surface to avoid flash blindness. It is known that this distance is directly proportional to the size
of the array in question23 but still requires further research to definitively answer.

The FAA Airport Facilities Terminal Integration Laboratory (AFTIL), located at the William J.
Hughes Technical Center at Atlantic City International Airport, provides system capabilities to evaluate
control tower interior design and layout, site selection and orientation, height determination studies,
and the transition of equipment into the airport traffic control tower environment. AFTIL regularly
conducts computer assessments of potential penetrations of airspace for proposed airport design
projects and has modeled the potential characteristics of glare sources, though not for solar projects.
AFTIL may be a resource for regional FAA officials and sponsors who seek to evaluate the potential
effects of glare from proposed solar projects.

Experiences of Existing Airport Solar Projects

Solar installations are presently operating at a number of airports, including megawatt-sized solar
facilities covering multiple acres. Air traffic control towers have expressed concern about glint and glare
from a small number of solar installations. These were often instances when solar installations were sited
between the tower and airfield, or for installations with inadequate or no reflectivity analysis. Adequate
reflectivity analysis and alternative siting addressed initial issues at those installations.

23
Ho, Clifford, Cheryl Ghanbari, and Richard Diver. 2009. Hazard Analysis of Glint and Glare From
Concentrating Solar Power Plants. SolarPACES 2009, Berlin Germany. Sandia National Laboratories.

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3.1.3 Communication Systems Interference

Communication systems interference includes negative impacts on radar, NAVAIDS, and infrared
instruments. Radar interference occurs when objects are placed too close to a radar sail (or antenna) and
reflect or block the transmission of signals between the radar antenna and the receiver (either a plane or a
remote location). Though it is possible for interference to be caused by other communication signals,
more commonly, it is caused by a physical structure placed between the transmitter and receiver.
However, similar concerns have been raised for airport-based navigational aids and communication
facilities. NAVAIDS can be impacted similarly to radar, but they include passive systems with no
transmitting signals. Impacts on infrared communications can occur because the solar panels continue to
retain heat into the first part of dusk and the heat they release can be picked up by infrared
communications in aircraft causing an unexpected signal.

Studies conducted during project siting should identify the location of radar transmission and receiving
facilities and other NAVAIDS, and determine locations that would not be suitable for structures based on
their potential to either block, reflect, or disrupt radar signals. Due to their low profiles, however, solar
PV systems typically represent little risk of interfering with radar transmissions. In addition, solar panels
do not emit electromagnetic waves over distances that could interfere with radar signal transmissions, and
any electrical facilities that do carry concentrated current are buried beneath the ground and away from
any signal transmission.

To ensure such systems are further isolated, past solar projects have also been required to be set back
from major on-airport radar equipment as a protected buffer. The solar fields at Oakland and Bakersfield
were required to meet setbacks from transmitters of 500 and 250 feet, respectively.

Off-airport solar projects are even more unlikely to cause radar interference unless located close to airport
property and within the vicinity of a radar equipment and transmission pathways. However, when located
near radar installation, CSP projects can cause reflection of radar transmission due to their metallic
components. Some reflections can be mitigated with Ram (radar absorbing material) coatings but these
can be cost prohibitive. One project located just outside the fence at the Phoenix Airport was reviewed by
FAA and conditions were placed on the Airspace Review approval to address potential concerns with
radar interference. In many cases, communication and coordination with the proper FAA officials can
mitigate the issues and concerns regarding solar power installations in and around airports.

3.2 Environmental Review

Like other development projects, solar facilities are subject to Federal, state and local environmental laws.
This section reviews the NEPA process which is applicable to Federally-funded projects and
environmental issues that might be reviewed under NEPA or by individual permitting agencies.

3.2.1 NEPA
The National Environmental Policy Act (NEPA) requires Federal agencies to evaluate the environmental
impacts of their actions and consider alternatives to mitigate potential impacts. For all new projects at
airports which require a Federal action, a NEPA review must be conducted. Federal actions can include a
change to the ALP, the issuance of a Federal permit or approval, or the granting of Federal funds. For
example, a ground-mounted solar project would trigger an update to the ALP and therefore require
environmental review under NEPA. However, a determination issued by the FAA under an airspace
review is not considered a Federal action and alone does not trigger a NEPA review. Roof-mounted
projects must be reviewed by NEPA if (1) the airport receives Federal funding or (2) the roof is leased to

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a private third-party. Solar PV projects previously reviewed under NEPA have received a Catex (CSP
facilities such as parabolic troughs and power towers may have different environmental issues as
determined under NEPA). After consulting with the Region or ADO about the project and environmental
issues, the sponsor will provide the FAA with environmental information to support a Catex or an
Environmental Assessment (EA). Past solar PV projects have received a Catex from the Region or ADO,
supported by background documentation on the purpose and need for the project and any potential
environmental impacts.24 The FAA will review the sponsor’s documentation for the project and issue a
determination that the project qualifies for a Catex, or if not, requires an EA. As with all categorically
excluded actions, FAA environmental specialists must evaluate extraordinary circumstances to ensure that
the FAA complies with its responsibility to minimize environmental impacts to specially protected
resources.

Several solar projects constructed at airports in recent years have been formally reviewed by the FAA for
NEPA compliance. These projects include the two solar facilities at Denver International Airport, and
facilities at Fresno and Bakersfield.25 Table 1 lists airports that have constructed solar projects and the
types of Airspace and NEPA reviews.

Table 1: Examples of FAA Regulatory Reviews for Existing Airport Solar Projects

Airport Project Type Airspace NEPA

San Francisco Roof None None
DIA – Pena Ground No Hazard Catex
DIA – Fuel Farm Ground No Hazard Catex
Fresno Ground No Hazard Catex
Bakersfield Ground No Hazard Catex
Albuquerque26 Roof None None
Boston Roof None None
San Jose Roof None None

24
The FAA is considering the development of a new Categorical Exclusion (Catex) for small solar energy projects.
25
Each sponsor applied for a Catex under Order 1050.1E 310 “Categorical Exclusions For Facility Siting, Construction, and
Maintenance” and provided supplemental information on site specific environmental issues to support the Catex determination.
Solar projects constructed on rooftops at Albuquerque (Phase I), San Francisco and Boston did not submit a NEPA application to
the FAA because no federal action was anticipated. A Catex was approved for the ground-mounted solar projects by citing the
following categories25:

310n – Minor expansion of facilities including the addition of equipment on an existing facility where no additional land
is required, or when expansion is due to remodeling of space in current quarters or existing buildings. Additions may
include antennae, concrete pad and minor trenching for a cable.

310r – Purchase , lease, or acquisition of three acres or less of land with associated easements
and rights-of-way for new facilities. (ATO)

310aa – Upgrading of building electrical systems or maintenance of existing systems, such as painting, replacement of
siding, roof rehabilitation, resurfacing or reconstruction of paved areas, and replacement of underground facilities.
26The first Project at Albuquerque was completed with no Federal money and therefore there was no Federal action. Phase two
of the project has received funding from the FAA and will be subject to NEPA review.

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Sponsors for any solar projects proposed at an airport must submit a 7460 form under Part 77 and either
appropriate documentation to support a Catex or an environmental assessment depending on the size and
potential environmental impact of the project. In both cases, the FAA strongly urges proponents to work
with the FAA early in the development process to facilitate a comprehensive and effective review. Once
the appropriate NEPA documentation is provided, the FAA will either issue a Finding of No Significant
Impacts (FONSI) or require the preparation of an Environmental Impact Statement (EIS).

3.2.2 Examples of Potential Environmental Issues

Because solar energy systems do not release any emissions or store any hazardous materials, potential
environmental damage is limited to impacts associated with land development. Even then, many projects
can be located on the roofs of existing structures that are already developed, thereby avoiding land
disturbance. Previously disturbed sites are also good candidates for solar installations because they will
not produce an increased impact. In fact, one of the advantages of constructing solar at airports is that
often much of the on-airport open space has been previously disturbed or is actively managed in
accordance with formal vegetative and wildlife management plans to keep it from penetrating airspace or
becoming a wildlife habitat. Still, such areas may provide environmental benefits that are subject to
regulatory review (see FAA Order 5050.4). The following environmental impacts are among the areas
that should be considered during a NEPA review and that may require Federal, state, or local permits.

Wildlife Habitat / Endangered Species

Wildlife habitat on airports typically includes habitats for species that prefer a grassland environment.
While the airfield environment is managed to be free of natural groundcover, shrubs, trees, and water
bodies that provide structure for shelter, foraging, and reproduction of wildlife, it can attract a specific
group of animals. Species that had to be considered during siting and design of past projects include
burrowing owl, kit fox, and grassland birds. Some of these species may be listed for protection under
Federal or state endangered species laws. Should the airport decide to proceed with a project at a site
where wildlife habitat may be impacted, the sponsor will need to characterize the extent of the habitat,
demonstrate how the project will minimize impacts, and mitigate for any unavoidable damage.

Water Quality Impacts from Erosion and Sedimentation

Construction projects disturb vegetation and soil and make it available to erosion causes by rain events.
The footprint of land disturbance for solar projects is limited to posts that hold up the ground-mounted
panels. However, construction vehicles needed to bring the panels and other materials to the site and
install the equipment can cause temporary impacts on the land that must be managed to avoid erosion and
sedimentation. The potential environmental impacts of erosion will vary considerably by region
depending on the time necessary to re-vegetate and stabilize disturbed areas. As an example, two years
after construction of its Pena Boulevard Solar Project, Denver International continues to maintain erosion
control and actively re-vegetate lands disturbed by construction.

Wetlands Disturbance

Wetlands are protected by Federal and state environmental laws due to their broad benefits to wildlife and
water quality. Projects that disturb wetlands or are proposed near wetlands may require the issuance of a
wetland permit. The permit may require land stabilization to prevent against erosion and sedimentation.
It may also require an assessment of alternatives to avoid and minimize impacts, and measures to mitigate
unavoidable impacts. For Denver’s Pena Boulevard Project, the developer connected two sections of the
project by drilling and installing a cable underneath a wetland to avoid a physical impact from traditional
trenching.

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Hazardous Materials

Hazardous materials are regulated by Federal and state laws. Because solar panels do not employ
hazardous materials, the use of them does not trigger an environmental review. However, if a project is
proposing to disturb land to construct a solar facility, the applicant may need to test the soil prior to any
work to ensure that historic contamination is not released from the soil. Should preliminary testing
suggest that soils may be contaminated with a regulated waste, it may be wise to avoid construction in
that area for both environmental and economic reasons.

Historic/Archaeological

Federal activities must comply with the National Historic Preservation Act. Many states also have
historic preservation programs that may encompass additional areas. Solar projects proposed for the roofs
of historic airport buildings may require approval to ensure that the solar panels do not adversely impact
the historic value of the structure. Ground-mounted projects that disturb soils may need to conduct an
archaeological study to ensure that below-ground historic resources are not impacted.

3.3 Off-Airport
Solar projects constructed off-airport are proposed and managed by private developers and public
agencies. They include a wide variety of technologies (PV, solar thermal, and concentrated solar power)
and sizes (residential, commercial, and utility-scale or grid-fed). While projects proposed on-airport have
a direct link with FAA authority and agency NEPA responsibilities, the need for FAA airspace review is
less clear the farther away projects are from the airport fence. The FAA has broad authority for airspace
review and the evaluation of any solar project that could pose a potential hazard to air navigation.

The clearest trigger for FAA review is a physical penetration of airspace. It is well-established that
structures rising 200 feet or greater above the land surface must be reviewed by the FAA. Tall structures,
such as wind turbines, cell towers, and communication antennae customarily rise above 200 feet and
proponents know that an airspace review is required. The FAA will review the location of structures and,
depending on their proximity to existing airports, will either limit their height to remain out of flight paths
or condition their approval to day and night obstruction lighting. Concentrated solar power projects with
power towers may rise to a height of 200 feet or greater, triggering an airspace review. Many other solar
projects including parabolic trough and PV farms will not and therefore the need to file a notice with the
FAA may not be clear.

Currently, no defined thresholds for project size, type, or distance from the airport are available that
automatically trigger FAA airspace review. However, proximity to the airport and CSP technology are
two indicators of likely FAA interest in a solar project.

Some utility-scale solar projects have been sited on Federal lands subsequent to a bid to lease land from a
Federal agency such as the Bureau of Land Management (BLM). Due to their location, these projects are
subject to NEPA review with the land holder (e.g., BLM, Air Force) acting as the lead Federal agency
coordinating the NEPA review. For these projects, mechanisms including Federal register notices and
inter-agency communications should be sufficient to alert the FAA that the project is proposed. It would
then be incumbent upon the FAA to inform the applicant that it requires an airspace review.

How the FAA is notified about potential impacts to airspace, or how it hears about pending solar projects,
varies. However, it is the responsibility of local governments, solar developers, and other stakeholders in
the vicinity of an airport to check with the airport sponsor and the FAA to ensure there are no potential
safety or navigational problems with a proposed solar facility, especially if it is a large facility. Likewise,

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sponsors must be aware of nearby off-airport activities that could have a negative effect on the safe and
efficient operation of the airport. Sponsors should notify the FAA when such activities are proposed and
FAA needs to participate in public meetings or permitting processes.

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Case Study #3 – Evaluating Airspace Issues

Metropolitan Oakland International Airport – California

Oakland International’s General Aviation Airport is host to a 756 kW ground-mounted system owned and
operated by a private company, which sells power back to the Port of Oakland at a discount. The project
consists of 4,000 fixed solar panels.

While the private developer was responsible as project applicant to file a 7460 Notice of Construction or
Alteration with the FAA for airspace review, it was critical that airport personnel play an active role in
assessing siting issues to ensure that the project would not produce a negative impact on airspace or
aviation activities. The airport is knowledgeable about FAA airport design standards and flight
operations, and works on a daily basis with FAA personnel in the Air Traffic Control Tower and ADO.

The three issues that Oakland evaluated during project siting were airspace penetration, radar
interference, and glare. Because it was exploring a location along a service road near the GA runway,
consideration of the imaginary surface extending out from the edge of Runway 6/27 was a critical
consideration even with low profile panels. As a result, the panels were located approximately 400 feet
from the runway avoiding any penetration of the imaginary surface of airspace. Second, the siting had to
consider the location of the panels relative to Navaids. A radar system is located to the west of the
proposed site. After consultation with the FAA, it was decided to preserve a 500-foot buffer from the
radar to protect against any interference. Third, the airport discussed the potential for glare to impact the
air traffic control tower. The FAA determined that, based on the available information, that glare would
not cause a negative impact. However, to ensure that it could address any unforeseen problem, the FAA
indicated that it would preserve the right to remove the project if a significant impact were to occur.

The project has been operational since November 2007 and there have been no reports of airspace impacts
from radar or glare on the air traffic control tower or on pilots. One of the keys to a smooth approval
process was close coordination between the airport, the solar developer, and the FAA from the earliest
phases of the project.

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 FAA Airport Solar Guide Chapter 4. Airport Solar Economics

4 AIRPORT SOLAR ECONOMICS: UNDERSTANDING THE

FINANCIAL INCENTIVES THAT MAKE SOLAR COST-
EFFECTIVE

Even with the free power of the sun, it has been a challenge for solar energy to compete with conventional
energy sources. Two factors that make solar electricity more costly are the efficiency of solar panels and
the cost of panel materials. Advances in technology have improved both, yet solar electricity can still
cost about three to four times more than its fossil fuel competitors. Other related factors influencing solar
economics are the intensity of the site’s solar resource (see Section 1.5) and site design, although the cost
to install a solar project is relatively uniform regardless of location. The viability of solar is also
determined by the existing cost of electricity and available financial incentives. This chapter reviews
electricity cost considerations and financial factors that can help airports determine project cost-
effectiveness and identify the best financing option(s).

For those seeking short-term returns, solar energy is probably not the right investment because equipment
costs are high and annual revenues (or cost savings) are low. The solar option is more attractive for those
looking at long-term financial benefits. In the future, solar pays back its costs and then provides “free”
electricity with little operations and maintenance expense. Solar also represents a form of insurance
which guarantees a long-term, predictable electricity price and avoids potential fluctuations in
conventional fossil fuel prices that are pinned to commodity prices influenced by supply and availability.
These factors make solar a good investment for long-term land uses, like airports. A checklist is provided
at the end of this chapter for doing a simple screening assessment of feasibility and solar potential.

4.1 Cost of Electricity

When existing electricity prices are low, it is difficult for solar to compete, but when existing electricity
prices are high, solar may be a viable option. However, the analysis is complicated by the variability of
conventional electricity costs over time.

4.1.1 Conventional Electricity

While we don’t know exactly what energy prices will be tomorrow, we do know where prices have been
historically, and where they are today. Based on national averages, conventional electricity prices have
increased by 38% in the past fifteen years.27

Prices also vary widely among individual states and regions of the country. Figure 18 provides
information on regional electricity prices in 2009. In that year, the northeast had the highest electricity
prices while Texas had the lowest. Updated monthly data for April 2010, shown in Table 1, indicates
that, even within the northeast, conventional electricity prices varied by as much as 35% from one New
England state to another. A simple conclusion might be that solar projects will be most cost-competitive
in Connecticut, not in Texas. However, the present-day cost of electricity is only one of three
fundamental project factors that must be considered along with the solar resource and financial incentives.

27
Electricity prices in creased from 6.86 cents per kilowatt-hour (kWh) in 1996 to 9.5 cents per kWh in 2010.
During that same period, prices peaked at 10.65 cents per kWh in July 2008. U.S. Energy Information
Administration. http://www.eia.doe.gov/

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Determining the cost effectiveness of solar electricity primarily involves three local factors:
1) Existing cost of electricity – where electricity prices are relatively high, solar is more economical
2) Strength of solar resource – the more sun, the more solar electricity produced, and the more revenue
3) State government incentives – state tax rebates or RPSs can make the difference

Figure 18: Average On-Peak Spot Electric Prices 2009 from Regional Transmission Organizations

Source: Federal Energy Regulatory Commission (FERC) National Electric Power Markets National
Overview - https://www.ferc.gov/market-oversight/mkt-electric/overview/2010.asp

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The top 10 states in terms of the cost of electricity (all sectors) for April 2010 are listed in Table 2 below.

Table 2: Highest Electricity Prices in April 2010

State Price (cents per kWh)

Hawaii 24.23
Connecticut 17.55
New York 15.95
Alaska 15.13
Massachusetts 14.84
New Hampshire 14.59
Rhode Island 14.10
New Jersey 13.69
District of Columbia 13.42
Vermont 13.04

Predicting future prices for conventional electricity presents other uncertainties. Recent price trends offer
some guide but energy forecasters have a difficult time predicting economic cycles, fossil fuel shortages,
or international political instability, all of which can have a major impact on the availability of fossil fuels
and the related price of electricity.

4.1.2 Solar Electricity

Unlike conventional electricity, the future cost of electricity from a solar facility is highly predictable
throughout the life of the project. While there will be small variations annually in the amount of sun
available for electricity production, other factors that influence the price of solar are known thus making
the margin of error small for predicting future electricity prices from solar.

The National Renewable Energy Laboratory has developed a solar energy calculator known as PVWatts
to help project developers predict expected solar production from a particular project site.28 Of the total
cost of a solar project over a 25-year
Solar electricity has a high initial investment, but few costs period, for example, 99% of costs can
during operations and maintenance. The key to solar be incurred in the initial investment.29
financing is to find a long-term customer for the electricity These costs include securing property
and to spread the payback of the initial investment over a rights, designing and permitting the
long-term contract. system, materials, construction, and
commissioning.

Future costs are limited to operations and maintenance, equipment replacement, and decommissioning.
Annual operating costs are about 0.02% of the total project cost. The only major expense during the
operational life occurs when the inverter fails, which is commonly planned for in the business model in
year 11. (The inverter converts the electricity from DC to AC – see Section 1.2.) Panel failure and
replacement is relatively uncommon, however the business model will factor in some panel replacements
as an anticipated cost.

28
National Renewable Energy Laboratory PVWatts Calculator - https://pvwatts.nrel.gov/
29
Photovoltaic Technologies - http://www.pvresources.com/en/economics/economics.php

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Long-term trends in the installed cost of solar PV have been decreasing, making solar electricity more
cost competitive. The price of solar has decreased by about 4% per year and is expected to continue to
decrease as a result of decreasing material costs and an increase in manufacturing efficiency.30

Electricity produced by solar panels (and therefore revenue generated) annually for a project’s 25-year
life can also be calculated accurately. Therefore, the financial key to a solar energy system is finding a
means for spreading the high initial project costs over the life of the project.

4.1.3 The Power Purchase Agreement

A Power Purchase Agreement (PPA) is a contract for electricity between a buyer and a seller. A PPA is a
key milestone in any renewable energy project because the PPA locks in a long-term revenue source for
the proposed power generation.

A PPA may be signed between a producer and a consumer who are physically connected, or it might be
executed between distant entities (requiring certification and issuance of RECs). In either case, with the
PPA, the developer can approach a financial institution (or private investors) that will lend money to the
project with assurances that they will be paid back over time from the revenues generated from electricity
production.

PPAs are generally executed between a private developer who sells the electricity and a consumer, who
could be public or private. Airports, which are public entities that may own and generate electricity,
typically do not execute PPAs because they are also the customer (though there may be a need for certain
interagency agreements as in the case of San Francisco’s agreement with a municipal utility). Utilities, on
the other hand, may be buyers of renewable energy through a PPA in order to satisfy state-mandated
renewable energy purchasing requirements under an RPS program.

Because airports are a large and reliable long-term electricity consumer, PPAs have been a successful tool
used by airports to develop renewable energy projects. Airports are often constrained from raising fees
on its customers to finance investments, particularly when the improvements are not fundamental
components of airport infrastructure. In addition, airports are not in the energy business and are more
suitable to serving as a host and long-term customer for the electricity as opposed to a developer of power
generation. By executing a PPA, the airport can avoid costs associated with project investment while
locking in a long-term price for the electricity source and budget for those utility costs, as appropriate.

30
http://www.solarbuzz.com/solarprices.htm

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In 2007, DIA was approached by a private solar developer about constructing a solar project on
airport property. The project concept made sense to the private developer because the airport had
good solar exposure for creating electricity, lots of space to site a project, and a long-term demand for
electricity. DIA was interested because the project could provide them with electricity at a rate
cheaper that it pays today and at a fixed price for 15 years. The developer and airport memorialized
their agreement through a PPA. But in order for the parties to agree to a price that achieved both the
profit objectives of the private developer and the price reduction objectives of DIA, funding was
required from the local utility, Xcel. Why would the Xcel contribute to the project when it pays lower
prices for electricity produced by fossil fuels? Because the Colorado legislature passed a law
requiring utilities to purchase a specific amount of renewable energy generated electricity annually, or
pay a fine larger than what it would pay for the “green” electricity. So Xcel issued an RFP requesting
bids to supply renewable energy generated electricity. The private developer offered to sell electricity
at a competitive rate when compared to other renewable energy alternatives. When Xcel selected the
project at DIA, it agreed to pay for the price premium of the renewables (in the form of RECs),
completing the financing and allowing all parties to achieve their financial objectives. The standard
ground lease and PPA used by DIA are provided in Appendix C and D, respectively.

4.2 Financial Incentive Programs to Lower the Cost of Solar

Governments have established a number of financial programs with the aim of incentivizing the
production of solar electricity. Those incentives take the form of tax credits, grants, rebates, loans, and
production payments. Public policies such as Renewable Portfolio Standards, Feed-in Tariffs, and net
metering may require the purchase of solar power. The DOE database of state incentives for renewables
and efficiency (DSIRE)31 provides a comprehensive and updated listing and description of Federal, state,
and local programs. The Solar Alliance Four Pillars Report describes how incentives, interconnection
policies, net metering policies, and utility rate and revenue policies represent the four most important
components of a robust state solar market.32 Direct cash incentives like rebates and production payments
have been central to sparking solar investment while interconnection and net metering policies that
restrict solar expansion act to dampen solar development. Installed capacity of solar projects is the best
measure of state incentive success. Table 3 lists the top ten States in terms to solar installations in 2009.

31
DSIRE database is managed by the North Carolina Solar Center and Interstate Renewable Energy Council. 2010.
32
http://www.solaralliance.org/downloads/four_pillars.pdf

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 FAA Airport Solar Guide Chapter 4. Airport Solar Economics

Table 3: Top Ten States in Solar Installations for 200933

State MWDC
California 212.1
New Jersey 57.3
Florida 35.7
Colorado 23.4
Arizona 21.1
Hawaii 12.7
New York 12.1
Massachusetts 9.5
Connecticut 8.7
North Carolina 7.8

These data represent all solar installations (e.g., residential, commercial) and do not directly translate into
the states with the best incentives for airport solar projects. For example, Florida’s 2009 installed
capacity is weighted by the 25 MW solar farm constructed by Florida Power and Light in DeSoto County
as well as by the localized incentives offered by the municipal utility in City of Gainesville. Otherwise,
Florida at this time does not offer highly favorable incentives for commercial-scale projects at airports.

The following section summarizes policies and programs available for airport solar projects.

4.2.1 Renewable Portfolio Standards

An RPS, also referred to more recently as a Renewable Electricity Standard (RES), is a government law
or policy that requires purchasing of renewable energy. Iowa was the first state to adopt an RPS in 1991,
followed by three other states in 1997. As of June 2010, 36 states and the District of Columbia had
adopted an RPS or renewable purchasing goal (see Figure 19). Congress is also considering proposals to
amend national energy policy to include a Federal RES mandate for renewable energy purchasing.

By enacting an RPS and requiring that some percentage of the electricity sold in a state come from a
renewable source, states have expanded the market for renewable energy. Under the program, electricity
purchasers, typically the electric utilities, must now find renewable energy generators and purchase their
electricity from such generators or be subject to penalty (referred to as a “Compliance Payment”) under
state law. Because the compliance payment is set at a price higher than the renewable price, purchasers
are incentivized to find renewable energy to purchase. Should the purchase of renewable energy result in
an increase in overall electricity costs to the purchaser, it will adjust its customers’ rates accordingly to
pay for the shortfall.

33
Interstate Renewable Energy Council - http://irecusa.org/wp-content/uploads/2010/07/IREC-Solar-Market-
Trends-Report-2010_7-27-10_web1.pdf

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 FAA Airport Solar Guide Chapter 4. Airport Solar Economics

Figure 19: Renewable Portfolio Standards in the U.S.

Source: Department of Energy DSIRE - http://ncsolarcen-prod.s3.amazonaws.com/wp-

content/uploads/2017/03/Renewable-Portfolio-Standards.pptx

4.2.2 Renewable Energy Credits

The most complex aspect of managing the RPS program is accounting for buying and selling of the
renewable energy. RECs have become the common “currency” for verifying that renewable energy has
been purchased and RECs are typically part of any renewable energy transaction accomplished under an
RPS/RES program. RECs are like a stock certificate issued by an independent organization that certifies
that a generator meets the definition of “renewable” and is generating renewable energy. The purchaser
(again, oftentimes the utility) acquires the RECs as part of its transaction for purchasing the renewable
energy. The purchaser then holds the RECs as verification of its purchase and presents them to state
regulators as necessary.

4.2.3 Tax Credits

Federal, state, and local governments which levy taxes to pay for government services may seek to
promote private investment in solar development by offering tax relief. The offer is to decrease the
amount of taxes owed based on the amount invested in renewable energy manufacturing or development

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 FAA Airport Solar Guide Chapter 4. Airport Solar Economics

projects. Because the incentive is associated with a reduction in tax payments, only private (taxpaying)
entities can take advantage of this opportunity.

There are two primary programs that have been created at the
Federal level through the Internal Revenue Service (IRS) to
apply renewable energy investments to a reduction in tax
payments: (1) investment or production tax credit, and (2)
accelerated depreciation.

The investment tax credit (ITC) and production tax credit

(PTC) both provide tax relief to a renewable energy developer
in an amount depending on the program available, which for
solar projects has been the ITC. Under the ITC, the IRS
approves a tax credit equal to 30% of the total project cost
amount invested to develop the project. The tax credit can be
claimed when filing Federal income taxes subsequent to the project going into service. The value of the
tax credit may be sold to other private entities, which have a tax interest and see an economic advantage
to partnering on the project. With the tax credit, the private entity never receives cash to help pay for a
project, but rather receives a credit on payments due, thereby producing a net positive on the company’s
balance sheet.

Another mechanism used to reduce project costs through tax relief is referred to as accelerated
depreciation. Future taxes must be paid on the value of installed equipment including investments in
renewable energy projects. As the equipment gets older, its value depreciates and tax payments based on
value will also depreciate. The IRS program called Modified Accelerated Cost Relief System (MACRS)
establishes a five-year period after which the equipment depreciation cycle is complete and taxes on value
no longer need to be paid. All of these measures are meant to provide tax relief to renewable energy
projects, including solar, to decrease expenses during operation and thereby produce electricity at a lower
cost.

Some states have enacted tax legislation where revenue departments offer similar tax credit programs on
state tax liability. Oregon, for example, offers businesses a 50% tax credit up to a maximum of $10
million. Developers must submit an application for preliminary certification where minimum technical
criteria are reviewed and approved prior to commencing construction.

4.2.4 Government Grants and Rebates

Tax incentives have been instrumental to catalyzing renewable energy projects. However, if given the
choice, energy developers would prefer to receive a grant or rebate payable in cash because cash is more
fungible than credit. Grants and rebates are less popular from a public policy perspective due to the need
for enhanced oversight, but have been used to speed the pace of renewable energy development projects.

Cash has also been provided to projects in the form of rebates. Rebates can be inter-changeable with
grants and may differ only in when they are approved and issued. In both cases, the generator will apply
for approval of the funding application in advance. A rebate is typically paid out after the project is
constructed and may be based on the unit of electricity produced. A grant may be paid before or after
construction.

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 FAA Airport Solar Guide Chapter 4. Airport Solar Economics

The Massachusetts Port Authority (Massport), which operates Boston Logan International Airport, is
using both public and private incentives to decrease the cost of electricity to be produced from a solar
array on the roof of Terminal A. Massport initially earmarked Federal stimulus money awarded to the
State’s Energy Program and allocated to Massport to pay down the upfront capital investment of a solar
project on Terminal A. Then it solicited public bids from solar companies interested in owning and
operating the facility. Following bid selection, Massport executed a PPA with the private developer to
buy the electricity produced by the system. The private developer was able to provide a cost-effective bid
for electricity price due to the reduced capital investment from a Federal stimulus grant and its ability to
monetize the tax credits. This will be Logan’s second solar project. The first is shown in Figure 20.

Figure 20: Solar Trees on Parking Garage at Boston’s Logan Airport

Source: Massport

4.2.5 Feed-In Tariff

Feed-in Tariff (FiT) programs have been popular in Europe but less so in the United States until recently
because a FiT fixes the price of the electricity produced rather than allowing markets to establish the price
(with or without subsidies). Additional components of the FiT include guaranteed access to interconnect
with the utility grid and a long-term contract (i.e., PPA) with the utility. The FiT program requires
utilities to buy renewable energy from all eligible participants, and establishes different prices for each
technology based on expected market costs. These programs encourage the development of a diversity of
energy projects because the cost of development is amortized.

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Germany enacted a FiT in 2000 and rapidly became the world leader in wind and solar manufacturing and
development. Today, Germany remains the leader in solar but dropped to second in wind behind the U.S.
after 200934. California was the first U.S. state to enact a FiT in 2008.

4.2.6 Bonds
Bonds allow government to raise money through borrowing. There are some examples of state and local
governments establishing bond authority for renewable energy projects. The government raises the
money to borrow by selling bonds with the intention of using money saved from the project in the long-
term to pay back bond buyers plus interest without additional tax or fee hikes.

Clean Renewable Energy Bonds (CREBs) were authorized by the Energy Tax Incentive Act of 2005. The
legislation permits state and local governments, cooperative electric companies, Native American tribal
governments, and public power providers to issue CREBs to finance clean energy projects. Under
CREBs, the bond issuer (e.g., local government) issues the bond and raises money. After the project is
constructed, the bond is repaid overtime with interest; however, the Federal government pays the interest
portion in the form of a tax credit. This allows the issuer to raise the money interest-free.

Funding for CREBs is authorized annually. While funding amounts have been notable, the reduction in
tax paying businesses during the economic recession has left the program underutilized over the past two
years, though a new provision in March 2010 allowed for a direct subsidy payment in lieu of the tax
credit. CREBs can only be utilized for projects owned by the borrowing entity (i.e., are not for privately-
owned, third party projects).

The County of San Jose 1.2 MW rooftop solar installation at Mineta San Jose International Airport
(see Figure 21) was built under the Terminal Area Improvement Program through project bonds. The
rental car companies are the County’s partners on the project and they needed to be comfortable with
the business case for the project on a long-term Return on Investment (ROI) basis. The economics of
the project greatly benefitted from an approximately $2 million solar incentive grant from the State of
California through the California Solar Initiative. Without the grant, the 20-year ROI would not have
been positive. Rental car companies and their customers are paying for 90% of the structure, as 90%
is dedicated for rental car operations. The other 10% is for public parking and is paid through the
airport. The companies pay via their long-term lease agreements with the airport, which is a
“residual” agreement meaning the cost and debt service for the structure, including solar, along with
operating costs, are secured through their lease payments. Customers also pay a “customer facility
charge” of $10 per transaction (a standard amount among California airports) that is also part of our
revenue stream that secures the rental car center costs. Thus, having a reasonable ROI on the solar
installation was essential. The overall capital cost of the rental car center (both for public parking and
rental cars, and including solar) is approximately $270 million.

34
REN21, (2009). “Renewables Global Status Report: 2009 Update,” Paris: REN21 Secretariat. Available at:
http://www.unep.fr/shared/docs/publications/RE_GSR_2009_Update.pdf

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 FAA Airport Solar Guide Chapter 4. Airport Solar Economics

Figure 21: Solar on New Rental Car Parking Facility at Mineta San Jose Airport

Source: San Jose County

4.2.7 Net Metering

Net metering is a form of performance incentive whereby the utility pays an energy generator for
electricity that is exported to the grid. Oftentimes, there is a requirement that some percentage of the
electricity generated be consumed on-site (by a factory, hospital, school) with the excess exported. The
utility then either purchases the exported electricity or credits the generator’s electricity account. When
the electricity is sent out to the grid, this is often referred to as “spinning the meter backwards” meaning
that the amount of electricity consumed on-site (and measured by the electrical meter) decreases (and the
amount paid for electricity also decreases).

Federal law requires utilities to purchase back exported electricity; however, the specific payments
associated with net metering programs vary among states. Factors that are considered in determining if
net metering is a cost-effective solution include: project caps for individual sites and annual allotments
within a utility’s service area; the price at which the utility must compensate the generator (wholesale or
retail price); and whether off-site bills can be credited by the exported energy (e.g., if municipality is the
generator, they can credit other electricity consumption accounts).35 Because net metering only helps
electricity exporters, many large and medium size airports cannot benefit because they will always use
more electricity on-site than is generated by a solar facility. However, small general aviation airports
might be able to capitalize on net metering programs.

35
Federal law and FAA policy regarding airport revenues and financially self-sustaining business practices for
airport sponsors require that airport operators preserve the value of airport assets. Airport sponsors may grant the
right to produce electricity on the airport to other parties that construct commercial improvements. These
agreements and net metering should align with the responsibility to pay for electricity consumed in an autonomous
relationship with the utility or electricity broker. Airport operators can provide lighting and other electrical utilities
in-common, under lease and use agreements, or to public areas of the airport not subject to lease or use agreements.
In this case, the airport operator must retain the revenue of electricity it produces. Also, generally speaking, airport
operators should retain the financial benefits of electricity generated on airport property for airport purposes and not
allow those financial benefits to be used for the non-airport interests of the broader municipal sponsor.

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4.3 Ownership Models

Public policy incentives provide different opportunities for different owners of solar energy projects.
Identifying the appropriate ownership model will vary depending on a combination of economic and
public policy factors specific to the project site.

The airport has two primary options when considering solar project development. The first is a solar
facility owned by the airport. The second is a facility owned by a private company - the model most
widely used by airports today. Regardless of who owns the solar facility, the same groups will be
involved in project development with the airport in the lead as property owner. Which ownership model
the airport selects will determine which financial incentives can be utilized and who owns the
environmental attributes of the project. An early-stage determination of ownership should consider the
following:

 Are tax incentives a significant portion of how the project will be paid for? Because there is a
30% tax credit available for all solar projects through the IRS, the answer to this question is
“yes.” Therefore all airport solar projects should consider the financial benefits of partnering
with a private company that can take advantage of the tax credits and pass those savings on to the
airport in the form of cheaper electricity. The counterbalance to this will be if government
funding (either from a municipal utility or from state or Federal energy programs) produces
greater benefits than the tax incentives. Bonds might also be a consideration.

 Is ownership of the environmental attributes important to the airport or city? Solar power has
value beyond just electricity because it is produced from clean, renewable sources. That value
can be realized either through a voluntary market (driven by customer demand for green power)
or a mandatory market (driven by a state RPS). In either case, the airport or municipality may
wish to own the value of the renewable energy (RECs). This benefit should be considered in the
ownership model because the owner of the facility owns the RECs.

This section describes the two primary ownership models and the advantages and disadvantages of each
option. Both models have proven to be successful and there are examples of airports that have done each.

4.3.1 Private Ownership – Airport as Host

The private ownership model offers the best approach for airports to develop solar especially in states
with attractive tax credits. In the private ownership model, the airport leases property to a private
developer granting them the right to construct, own, and operate a solar facility. The basic contract is a
land (or roof) lease with a $ per unit rental fee, annual escalators, and term of lease. To make the project
worthwhile, the developer will likely seek a long-term lease of 10-30 years. The land lease agreement
will often include options for the airport to buy the facility back from the developer and terms and
conditions of such an option. Figure 22 illustrates the fundamental transactions of this model.

The developer owns the solar facility, the electricity it produces, and the green benefits associated with it.
Typically, the airport will also execute a PPA with the developer to purchase the electricity produced by
the solar facility for a specific price over a long-term period. It is possible that the developer could
execute a PPA with another entity (other department of government, nearby business), however, it is
easier to have one contract with the airport for both land lease authority and electricity purchase. The
utility may acquire the RECs if it has a mandate to purchase renewable energy under a state RPS
program. At a minimum, it will review the technical specifications of the electrical interconnection and
issue an interconnection permit.

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The developer permits, constructs, owns, operates, and maintains the facility for the life of the project.
Because profitability is entirely dependent upon the efficient operation of the facility, the developer is
sure to take good care of their investment.

Advantages: The private ownership model is fundamentally a simpler proposition for the airport if not
more economical in the long-term. It requires no capital investment from the airport. It requires no
specialized expertise on solar energy from the airport. The sponsor is seen as being proactive on
environmental and energy issues and responding to the concerns of the community without taking on the
risks associated with owning and operating the solar facility.

Disadvantages: The primary disadvantage to the private ownership model is that the sponsor releases
control of the project and the associated project. A secondary drawback is that the airport will not
achieve a payback point and begin receiving free electricity. Instead, the sponsor is locked into paying
for the electricity (assuming a lower than market rate) for the life of the contract unless it exercises an
option.

Funding: Engaging a private partner to develop a solar project allows the project to take advantage of the
tax credits with those savings being passed on to the airport through a lower cost in the PPA. The tax
credits are a more certain subsidy than competing for government grants. The Federal tax credit alone,
however, has not been enough to attract private investment which has focused on states that provide
supplementary tax credits. It is possible that projects can be structured with both a Federal grant to pay
down the cost of the initial capital investment, and by executing a lease with a private partner who can
capitalize on the tax credits.

Figure 22: Private or Third-Party Owned Business Model

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4.3.2 Public Ownership – Airport as Owner

In the public ownership scenario, the airport owns the solar facility and utilizes the electricity and
associated “green” benefits on-site. The sponsor contracts with a design-build firm to construct and
commission the project. It executes a separate contract for operations and maintenance. The utility’s
primary role is to conduct a technical review of the facility to ensure its compatibility with the electric
grid, and issue an interconnection permit approving the project. It is possible that the utility could also
purchase the renewable energy credits from the sponsor to satisfy RPS requirements which will also
further reduce the cost of the electricity produced. Electricity generated by the project is used by the
airport to offset future purchases from the grid. The project pay-back period is reached when the savings
from electricity that otherwise would have been purchased from the grid equals the cost of the project
investment. Figure 23 displays a more simple bilateral business relationship of the public model.

Advantages: As owner of the solar project, the sponsor provides no rights to its property to a private
energy company. Assuming all factors are equal, the cost of the project is less over the life of the project
(e.g., 25 years) than private ownership where long-term airport electricity payments also pay for the
private company’s return on investment. This leads to a point in the future where the solar facility is
entirely paid off and is providing free electricity to the airport for the cost of maintenance.

Disadvantages: Owning a solar project could also mean owning any responsibilities associated with
project management, working with contractors, and overseeing performance guarantees and warranties.
While these issues are no different (or riskier) than any other construction project on airport land, the
technical issues associated with solar energy development may present some challenges beyond those
associated with typical building systems and airport support structure. While public ownership results in
a less costly project over the project life, it also requires funding the capital investment.

Figure 23: Airport Owned Business Model

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Funding: The subsidies for solar projects and other renewables have been weighted towards tax credits
that spur private investment. Because airports as non-taxpaying entities are not eligible for the tax credits,
private developers have been more successful in proposing cost-effective solar projects than public
entities. However, those opportunities have been most competitive in States that offer their own tax credit
programs in addition to the Federal investment tax credit (ITC). State variations in public policy have
created regional imbalances where solar projects are concentrated in certain States.

Ownership structure for existing airport solar projects is summarized in Table 4.

Table 4: Examples of Ownership Structure for Existing Airport Solar Projects

Business Owner/
Airport Electricity Purchase RECs
Model Operator

Private Renewable PPA – Airport purchase Developer sells

Denver #1
Third Party Ventures from owner to Utility

Private PPA – Airport purchase Developer sells

Denver #2 Oak Leaf Partners
Third Party from owner to Utility

City of No purchase
Albuquerque Airport Owned Albuquerque, – direct use on airport; Owned by City
Aviation Dept offsets grid

Private Solar Power PPA – Airport purchase Developer sells

Fresno
Third Party Partners from owner to open market

Public Utility Airport purchases at set

San Francisco SF Public Utility Owned by City
Owned commercial retail rate

Private PPA – Airport purchase Developer sells

Oakland Sun Edison
Third Party from owner to open market

Private PPA – Airport purchase Developer sells

Bakersfield Regenesis
Third Party from owner to open market

* No Federal funds were directed to the airports for any of these projects.

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FAA Airport Solar Guide Chapter 4. Airport Solar Economics

The City of San Francisco has ambitious greenhouse gas reduction goals and has appropriated
resources to achieve those goals. As part of this program, the City has been identifying municipal
buildings to be retrofitted with solar PV. The San Francisco Public Utility Company (PUC)
approached the airport about hosting a solar facility as part of this program and in 2007 the PUC
funded the construction of a 450 kW solar PV system on the roof of Terminal 3 at San Francisco
International Airport. Under the contractual arrangement, the airport buys the electricity that is
produced by the solar panels at the typical commercial electricity rate so that there is no cost impact of
the solar on the airport budget. The project is shown as Figure 24.

Figure 24: Rooftop Solar Project on San Francisco’s Terminal 3

Source: City of San Francisc

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Case Study #4 – Partnering with a Private Developer

Meadows Field – Bakersfield, California
Meadows Field in Bakersfield, California is host to a 744 kW AC ground-mounted solar generation
system owned and operated under a lease contract with a private developer. The project consists of 4,704
185-kW solar panels on a single axis tracking system.

The developer and Kern

County, which operates the
airport, signed a PPA under
which the county agrees to
purchase all of the electricity
produced by the solar facility
at a pre-determined price over
a 20 year contract period.
The panels produce enough
electricity to serve
approximately 75% of the
airports annual average
electricity load. However,
because the electricity use of
the airport is not always in-
sync with the electricity
output of the solar facility, the
airport both receives
electricity from the electric grid (e.g., in the evening), and exports Source: City of Bakersfield
electricity (during maximum output). In the middle of the afternoon when
exporting occurs, the airport is selling electricity back to the utility company under a net metering
agreement. This is also referred to as “spinning the electric meter backwards.” This is a good time for
the airport to be paid for electricity because it is valued at peak rates when demand for electricity on the
overall grid is high. Conversely, when the airport is purchasing electricity from the grid, it is during off-
peak hours when electricity rates are lower.

The benefits to the airport are a 20-year fixed price for electricity, which when compared to long-term
averages in market rate electricity, will amount to a 16% savings in electricity payments; a lease payment
from the developer over the 20 year contract of $0.01/s.f./year for the 6 acre project area; and half of the
value of the RECs produced by the project. RECs will soon be sold by renewable energy producers to
others who want to offset carbon emission taxes. Renewable Energy Certificates, which are publicly
traded environmental commodities, are not monetized yet. Once a market price has been established, the
RECs, which are split 50/50 between the sponsor and developer, should be worth between $0.01 to
$0.08/kWh of energy produced over the life of the system. A 50% share at $0.01/kWh should be worth
around $150,000 annually.

The private developer can take advantage of accelerated depreciation and investment tax credits and split
those savings with the airport as part of the PPA electricity price. By securing a long-term customer for
its electricity, the developer can operate a profitable solar project.

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Table 5: Feasibility Checklist for Airport Sponsors

Issue Consideration Yes or No

Initial Screening

Solar Resource Is there enough solar resource? (See Figure 9)

Are there extreme weather events or conditions that should be
Extreme Weather
considered that might increase installation costs?
Electricity Demand Can the electrical output be used on-airport to enhance economics?
Is there a combination of robust state incentives and high existing
State Incentives / Electricity Price
electricity prices that will make solar cost-competitive?
Are there space constraints that will limit project size and impact
Space Constraints
economics?
Site Selection
Does the airport have non-aeronautical airfield land available for
Land vs. Building
solar?
Competing Uses Has a fair market value been determined?
Are ALP changes needed and have they been approved by the
ALP Designation
FAA?
Has the Form 7460 been filed and has a glare analysis been
Glare
reviewed by the FAA?
Is the project located on undisturbed land requiring consultation
Environmental
with Federal and state environmental agencies?
Can the project be sited close to existing electrical meters to
Proximity to Electrical Load
minimize the costs associated with interconnecting cables?
Financing

Airport Revenue Retention Are project revenues being kept for aviation uses?

Tax Incentives Are there enough state incentives to benefit the project cost?

Grants/Rebates Are there any grants or rebates available?

Loans/Bonds Are loans and bonds an option and are the rates beneficial?

Production Payments (RECs) Is there a state RPS?

Do the financial instruments available clearly favor private or
Private or Public
public ownership?

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 FAA Airport Solar Guide Chapter 5. Federal Role in Solar Development

5 THE FEDERAL ROLE IN AIRPORT SOLAR DEVELOPMENT

The Federal government encourages, through a variety of policies and programs, the development of
technologies that take advantage of the clean abundant energy of the sun and provide a secure and reliable
source of domestic energy production. The benefits of solar energy extend to important national goals of
greater energy independence, clean air, and the control of greenhouse gases affecting climate change that
ultimately affect the quality of life for all citizens.

Federal assistance for solar energy is provided through several means, including tax credits (see Chapter
3), research and demonstration programs, funding initiatives, technical assistance, and public information
services. The lead Federal agency in the solar arena is the U.S. Department of Energy (DOE). The DOE
directs national energy policy and balances Federal priorities for energy development and efficiency
including the management of solar energy programs.

DOE programs for solar energy are located under the Assistant
Secretary for Energy Efficiency and Renewable Energy (EERE). The
DOE State Energy Program (SEP) provides grants and technical
assistance to states for renewable energy and sustainability projects.
The SEP Program is the only program in EERE that provides
substantial outreach and funding for local solar projects. The Solar
Energy Technologies Program (SETP) supports solar research and
development, systems integration, and market transformation
initiatives for high-profile partnership projects. SETP also provides
technical assistance to local, state and Federal government entities on
technical and policy/regulatory issues. More information on SEP and
SETP programs can be found at the DOE web site.36

5.1 Executive Orders for Energy Management and Sustainability

Executive Order 13423, Strengthening Environmental, Energy, and Transportation Management of
Federal Agencies, is a major impetus for new Federal agency energy management and sustainable energy
policies including encouraging the development of renewable energy projects.37 EO 13423 requires
Federal agencies to lead by example in advancing the nation’s energy security and environmental
performance targets. Among the directives to Federal agencies, EO 13423 includes the following energy
goals:

 Improve energy efficiency and reduce greenhouse gas emissions from the agency by reducing
energy consumption by 3 percent annually through 2015 or by a total of 15% by the end of fiscal
year 2015 (relative to fiscal year 2003).

 Ensure that at least half of the agency’s renewable energy consumption in a fiscal year is from
new renewable sources, and the agency should implement renewable energy generation projects
on agency property to the extent feasible.

36
www.doe.gov
37
Initiated by President Clinton, re-signed by President Bush in 2007 and codified into law with the passage by
Congress of the Omnibus Act of 2009, which was signed by President Obama in February 2009.

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 FAA Airport Solar Guide Chapter 5. Federal Role in Solar Development

 Ensure that, if the agency operates a fleet of more than 20 motor vehicles, it (i) reduce the fleets
total consumption of petroleum products by 2% annually through the end of fiscal year 2015
(compared to the 2005 baseline), (ii) increase fuel consumption of non-petroleum-based fuels by
10 percent annually, and (iii) use plug-in hybrid vehicles where cost-effective based on a life
cycle analysis.

Based on EO 13423, the FAA issued Order 1050.21 in 2007, mandating the development of an internal
FAA Environmental Management System (EMS).38 The EMS is designed to identify potential
environmental impacts from FAA activities and to improve agency environmental performance on a
continual basis. In addition, the Office of Airports is proposing an Advisory Circular to sponsors on how
to develop and implement an airport EMS, which several airports around the country have already
accomplished to standard.

Executive Order 13514 of 2009, Federal Leadership in Environmental, Energy, and Economic
Performance requires Federal agencies to develop an inventory of their greenhouse gas emissions and to
quantify long-range targets for greenhouse gas reduction. 39 When establishing targets, Federal agencies
must consider reductions of energy intensity in Federal buildings and increased use of renewable energy
sources in all Federal facilities and vehicle fleets. Federal agencies are also encouraged to coordinate
with the private sector to develop incentives for vendors and contractors that use green technologies.

5.2 FAA Policy and Planning

The FAA is incorporating energy management and sustainability goals into many of the agency’s policy
and planning documents. For example, energy management is cited in the 2010 FAA Business Plan as a
core objective:

“provide guidance and coordinate [FAA] efforts to plan, implement, and document agency
energy management activities to address national mandates without adverse effects on the
national aviation system.”40

In addition, the Office of Airports has included sustainability in its proposed 10-year strategic plan as one
of the five major organizational goals along with safety, mobility, workforce, and international subject
areas.

Most importantly perhaps, the FAA is exploring a variety of environmental and sustainability initiatives
as part of the agency’s major planning initiative for the future the Next Generation Air Transportation
System (NextGen). NextGen provides the agency’s long-term blueprint for bringing promising research
on alternative aircraft fuels to commercialization and implementing new navigational systems that greatly
improve flight track and procedural efficiencies to reduce fuel burn and emissions. NextGen initiatives
for airports will include funding to critical areas of airport infrastructure expansion, including
environmental improvements that reduce airport carbon footprints.

38
Order 1050.21 was issued on October 30, 2007 by Robert Sturgell, Acting Administrator for the FAA.
39
Signed by President Obama on October 9, 2009.
40
Aviation Policy, Planning, and Environment: Fiscal Year 2010 Business Plan, November 2009.

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 FAA Airport Solar Guide Chapter 5. Federal Role in Solar Development

5.2.1 Possible Strategies for Solar Development

Underlying FAA’s general support of sustainable airport development is the agency’s primary interest in
ensuring that solar projects do not interfere with safe and efficient air transportation. The FAA exercises
its safety responsibilities regarding solar development under Part 77 authority (see Chapter 3).

Provided aviation safety is insured, the FAA may be able to facilitate solar development in several ways
that help sponsors design and build modern and efficient solar facilities that save energy, reduce local
emissions and greenhouse gases, and lower airport operating costs. Possible strategies include:

 Expanding the use of solar energy for FAA facilities and operations.

 Developing FAA sustainability and energy goals that lead to new investments in solar by the
aviation community.

 Providing sponsors with information through this guide and other means to help them explore the
best options for solar technology, financing, and construction. This includes informing sponsors
of the regulatory requirements for solar development and the need for early coordination with the
FAA to ensure timely FAA review and approvals.

 Encouraging sponsors to incorporate practical opportunities for solar energy in their long-term
master planning process.

 Supporting research initiatives that will contribute to improved siting, design, and safety
standards for airport solar facilities as well as greater efficiencies in the FAA review process.

5.2.2 FAA Airport Engineering Guidance

The FAA is putting increased emphasis on sustainability in its airport planning and design programs. The
growing acceptance of sustainability in airport planning has grown out of recognition that efficient energy
use and environmental design are cost-effective over the long-term and a smart investment in the nation’s
aviation infrastructure.

The FAA has produced guidance on sustainability planning that demonstrates its commitment to
sustainable airport development. For example, the FAA Design Handbook for Energy Efficiency and
Water Conservation at National Airspace System Facilities states that the FAA should use
alternative/renewable power sources where they are shown to be cost-effective.41 In addition, Advisory
Circular 150/5360-9, Planning and Design of Airport Terminal Facilities at Non-hub Locations, states
under the energy conservation section that:

“solar architecture can be incorporated in new or existing buildings to replace or supplement

conventional heating systems. Active and/or passive systems can utilize the sun's energy to
considerably reduce energy usage in buildings for space heating.”42

5.2.3 Airport Sustainability Planning

Wise energy use including the generation of renewable energy is central to sustainability programs. The
FAA Airports Office initiated an airport sustainability pilot program in 2010. The 10 sponsors

41
Design Handbook: Energy Efficiency and Water Conservation at NAS Facilities. September 30, 1997. See
Section 5. Alternative and Renewable Electric Power Sources should be utilized in accordance with FAA 6980.26.
42
AC 150/5360-9 was issued April 1980.

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 FAA Airport Solar Guide Chapter 5. Federal Role in Solar Development

participating in the pilot program are conducting one to two year studies of cost-effective sustainability
measures at their airports. Six of the studies will be stand-alone sustainability management reports while
the remaining four studies will be incorporated into separate chapters of Airport Master Plan Updates.
Participating airports were selected based on geographic variability and airport operations (3 Large Hubs,
1 Medium Hub, 3 Small Hubs, 1 Reliever, and 2 General Aviation).

The FAA hopes that the results of the sustainability pilot program will yield a clear direction for the
agency in the years ahead. Based on the findings, the FAA is likely to pursue more permanent initiatives
in the area of sustainability, including solar energy.

5.3 FAA Airport Funding

Sponsors often need additional resources to identify the
potential for solar energy and to plan and build a solar The FAA expects that private
facility. The FAA recognizes that the most effective investment will continue to be the
strategy for sponsors to accomplish this planning and most attractive financing option for
development is through private financing absent any airports in the future.
Federal assistance. The private sector has already
developed a proven track record of designing and
operating successful airport facilities around the country. Private financing takes advantage of revenues
generated from the solar generation of electricity and a complementary package of Federal and state tax
incentives and utility renewable energy programs. Sponsors benefit financially from long-term electricity
price savings and lease payments. Successful airport projects have been constructed by private
developers in California, Colorado, and Massachusetts.

However, the FAA also recognizes that the viability of the private market today is limited geographically.
For solar to be economical, a number of financial incentives must be present. Federal tax rebates alone do
not guarantee profitability, nor is there a Federal Renewable Energy Standard (RES), which would require
utilities in all states to purchase a percentage of the electricity that they deliver to customers from
renewable sources. On the state level, many States do not offer meaningful tax incentives or RES
programs to spur renewable energy development. Airports located in such states are unlikely to be
approached by private investors. Consequently, future FAA activity in this area may need to focus on
existing gaps until solar technology prices come down in relation to conventional fuel prices or until
larger and more uniform Federal and state tax policies are established.

5.3.1 AIP and PFC Programs

Because most airports have suitable buildings and lands to host solar facilities, future demand for solar
funding may be substantial. Therefore, the limited FAA eligibility and funding for the environment
dictates that proposed solar projects provide significant benefits and compete effectively with other FAA
and airport development priorities.

Airports may be eligible under the FAA Airport Improvement Program (AIP) and Passenger Facility
Charge Program (PFC) to receive funding for cost-effective solar applications that are an essential or
integral part of the design of an approved terminal building design or development project. Stand-alone
solar projects are not currently eligible under AIP and the PFC Program, unless proposed through the
FAA Voluntary Airport Low Emission Program (see below).

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 FAA Airport Solar Guide Chapter 5. Federal Role in Solar Development

5.3.2 VALE Program

The FAA Voluntary Airport Low Emission Program (VALE) was established in 2005 under the AIP and
PFC Programs to provide sponsors with funding for low-emission projects to meet the requirements of the
Clean Air Act. The program is available to commercial service airports located in EPA-designated
nonattainment and maintenance areas. Details of the VALE program can be found at the VALE web site:
(www.faa.gov/airports/environmental/vale)

Because the VALE program is designed to address local air quality and criteria pollutants regulated by
National Ambient Air Quality Standards, only solar projects located in EPA-designated areas are eligible
for VALE funding. Further, only projects that reduce emissions on the airport can be considered for
VALE funding. This has implications for solar projects that can be considered under the VALE program.
Solar thermal projects (e.g., passive solar walls and water heating systems) are more suitable for the
program because they offset heating and cooling emissions fueled by a gas or oil fired burner operating at
the airport. In contrast, solar PV projects are often not suitable for VALE funding because they typically
reduce airport electricity usage that is delivered through the electrical grid. In those cases, the emissions
reductions actually occur at the off-airport power plant.

Sponsors should contact the Region or ADO early in the established AIP and PFC planning cycle if they
are considering a proposed project under the VALE program.

5.3.3 FAA Airport Energy Efficiency Program

Section 512 of the FAA Modernization and Reform Act of 2012 (FMRA), “Increasing the Energy
Efficiency of Airport Power Sources,” and codified at 49 U.S.C. § 47140a, directed the Secretary of
Transportation to establish a program to encourage the sponsor of each public-use airport to assess their
energy requirements in order to identify opportunities to improve the airport’s energy efficiency. It also
encouraged the Secretary to consider grants for certain energy efficiency projects.

Certain solar projects may be eligible under this program. However, eligibility greatly depends on the
type of project and availability of regular AIP discretionary funding. Sponsors should contact the Region
or ADO early in the established AIP and PFC planning cycle if they are considering a proposed project
under this program.

5.4 Recommendations
In the process of conducting the background research for this Guide and analyzing the information
collected, the FAA has identified several areas affecting airport solar development that need further
research or development. Specifically, the FAA recommends the following:

1. Further research and development of reflectivity and communication systems interference

standards for solar projects and related analysis requirements, especially for CSP technology.

2. Design and development of new assessment tools for modeling and evaluating solar projects.

3. Development of a specific NEPA categorical exclusion (Catex) for small solar projects.

4. A cost-benefit analysis of airport solar applications that compares alternative solar technologies
(e.g., PV, thermal, and parabolic) with site design alternatives (e.g., building vs. ground
mounting; tracking vs. fixed mounting).

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 FAA Airport Solar Guide Chapter 5. Federal Role in Solar Development

Case Study #5 – Building on Local Initiatives

Albuquerque International Sunport – New Mexico
The City of Albuquerque
constructed a 146 kW
roof-mounted solar
generation system on
existing parking structures
at the Albuquerque
International Sunport in
September 2009. The
project consists of 480
305-watt solar panels on a
fixed mount system. The
electricity is used for
lighting throughout the
parking garage.

The project was an

initiative of the
Albuquerque Green
Program which seeks to
Source: City of Albuquerque
demonstrate the City’s
leadership by making wise and innovative choices to ensure that Albuquerque is a sustainable
community. Building on the first project, the City approached the FAA with a proposal to obtain funding
for a portion of the second phase under the Voluntary Airport Low Emissions Program (VALE). The
second phase project, which was recently approved for funding by the FAA, will add 438 kW of solar
capacity to the existing facility and offset regional air emissions from fossil fuel power plants.

The project is a demonstration of how the FAA can target funding to airports for solar projects and
produce regional air quality benefits by removing a portion of the airport’s electricity demand from the
electric grid and replace it with emissions-free generation. Future solar projects to be considered for
funding under VALE will need to meet the standards set by the Albuquerque example including system
ownership by the airport, significant air quality benefits full emission reduction credits from the State or
local air quality agency, and no diversion of revenue generated from the long-term sale of RECs,

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FAA Airport Solar Guide Appendix A. FAA Contact Information

Appendix A. FAA Contact Information

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 FAA Airport Solar Guide Appendix A. FAA Contact Information

Contact Information for FAA Offices

HEADQUARTERS

Federal Aviation Administration

Office of Airport Planning and Programming (APP)
800 Independence Avenue SW
Washington DC 20591
(202) 267-8775 – Tel.
(202) 267-5302 – Fax

REGIONS AND AIRPORT DISTRICT OFFICES

Alaskan Region
(Alaska)

Federal Aviation
Administration
Airports Division, AAL-600
222 West 7th Avenue M/S
#14
Anchorage, AK 99513-7587
(907) 271-5438 – Tel.
(907) 271-2851 – Fax

Physical Address:
222 West 8th Avenue
Room 336
Anchorage, AK 99513

Central Region
(Iowa, Kansas Missouri, Nebraska)

Federal Aviation
Administration
Airports Division, ACE-600
901 Locust, Rm 364
Kansas City, MO 64106-
2325
(816) 329-2600 – Tel.
(816) 329-2610/2611 – Fax

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FAA Airport Solar Guide Appendix A. FAA Contact Information

Eastern Region
(Delaware, District of Columbia,
Maryland, New Jersey, New York,
Pennsylvania, Virginia, West Virginia)

Federal Aviation
Administration
Airports Division, AEA-600
Eastern Region
1 Aviation Plaza
Jamaica, NY 11434
(718) 553-3330 – Tel.
(718) 995-5694 – Fax

Physical Address:
159-30 Rockaway Blvd
Jamaica, NY 11434

Harrisburg Airports District Office New York Airports District Office

(Delaware, New Jersey, Pennsylvania) (New York)

Federal Aviation Administration Federal Aviation Administration

3905 Hartzdale Drive, Suite 508 1 Aviation Plaza, Room 111
Camp Hill, PA 17011 Jamaica, NY 11434
(717) 730-2830 – Tel. (718) 995-5770 – Tel.
(717) 730-2838 – Fax (718) 995-5790 – Fax

Washington Airports District Office Beckley Airports Field Office

(District of Columbia, Maryland, Virginia) (West Virginia)

Federal Aviation Administration Federal Aviation Administration

23723 Air Freight Lane, Suite 210 176 Airport Circle, Room 101
Dulles, VA 20166 Beaver, WV 25813-9350
(703) 661-1355 – Tel. (304) 252-6216 – Tel.
(703) 661-1370 – Fax (304) 253-8028 – Fax

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FAA Airport Solar Guide Appendix A. FAA Contact Information

Great Lakes Region

(Illinois, Indiana, Michigan Minnesota, North
Dakota, Ohio South Dakota, Wisconsin)

Federal Aviation Administration

Airports Division, AGL-600
2300 East Devon Avenue
Des Plaines, IL 60018
(847) 294-7272 – Tel.
(847) 294-7036 – Fax

Chicago Airports District Office Dakota-Minnesota Airports District Office

(Illinois, Indiana, Wisconsin) (Minneapolis, North Dakota, South Dakota)

Federal Aviation Administration - Minneapolis Office

Chicago Airports District Office, CHI-
ADO-600 Federal Aviation Administration
2300 East Devon Avenue Dakota-Minnesota Airports District Office,
Des Plaines, IL 60018 MSP-ADO-600
(847) 294-7336 – Tel. 6020 28th Avenue South, Room 102
(847) 294-7046 – Fax Minneapolis, MN 55450
(612) 253-4610 – Tel.
(612) 253-4611 – Fax

Detroit Airports District Office - Bismarck Office

(Michigan, Ohio)
Federal Aviation Administration
Federal Aviation Administration Dakota-Minnesota Airports District Office,
Detroit Airports District Office, DET- BIS-ADO-600
ADO-600 2301 University Drive, Bldg 23B
11677 South Wayne Road, Suite 107 Bismarck, ND 58504
Romulus, MI 48174 (701) 323-7380 – Tel.
(734) 229-2900 – Tel. (701) 323-7399 – Fax
(734) 229-2950 – Fax

New England Region

(Connecticut, Maine, Massachusetts, New Hampshire, Rhode
Island, Vermont)

Federal Aviation Administration

Airports Division, ANE-600
1200 District Avenue
Burlington, MA 01803
(781) 238-7600 – Tel.
(781) 238-7608 – Fax

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FAA Airport Solar Guide Appendix A. FAA Contact Information

Northwest Mountain Region

(Colorado, Idaho, Montana, Oregon, Utah, Washington,
Wyoming)

Federal Aviation Administration

Airports Division, ANM-600
2200 S 216th Street
Des Moines, WA 98198
(206) 231-4100 – Tel.
(206) 231-[STAFF EXT] – Fax

Denver Airports District Office Helena Airports District Office

(Colorado, Utah, Wyoming) (Idaho, Montana)

Federal Aviation Administration Federal Aviation Administration

Northwest Mountain Region Northwest Mountain Region
Denver Airports District Office Helena Airports District Office
26805 East 68th Avenue, Suite 224 FAA Building
Denver, CO 80249-6361 2725 Skyway Drive, Suite 2
(303) 342-1254 – Tel. Helena, MT 59602-1213
(303) 342-1260 – Fax (406) 449-5271 – Tel.
(406) 449-5274 – Fax

Seattle Airports District Office

(Oregon, Washington)

Federal Aviation Administration

Northwest Mountain Region
Seattle Airports District Office
2200 S 216th Street
Des Moines, WA 98198
(206) 231-4145 – Tel.
(206) 231-[STAFF EXT] – Fax

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FAA Airport Solar Guide Appendix A. FAA Contact Information

Southern Region
(Alabama, Florida, Georgia, Kentucky,
Mississippi, North Carolina,
Tennessee, South Carolina, Puerto
Rico, U.S. Virgin Islands)

Federal Aviation
Administration
Airports Division, ASO-600
1701 Columbia Ave., Suite
540
Atlanta, GA 30337
(404) 305-6700 – Tel.
(404) 305-6730 – Fax

Atlanta Airports District Office Jackson Airports District Office

(Georgia, South Carolina,Puerto Rico, U.S. Virgin Islands) (Alabama, Mississippi)

Federal Aviation Administration Federal Aviation Administration

Atlanta Airports District Office Jackson Airports District Office
1701 Columbia Avenue, Suite 220 100 West Cross Street, Suite B
College Park, GA 30337 Jackson, MS 39208-2307
(404) 305-6799 – Tel. (601) 664-9900 – Tel.
(404) 305-6798 – Fax (601) 664-9901 – Fax

Memphis Airports District Office Orlando Airports District Office

(Kentucky, North Carolina, Tennessee) (Florida)

Federal Aviation Administration Federal Aviation Administration

Memphis Airports District Office Orlando Airports District Office
2600 Thousand Oaks Blvd, Suite 2250 8427 South Park Circle, Suite 524
Memphis, TN 38118 Orlando, FL 32819
(901) 322-8180 – Tel. (407) 487-7220 – Tel.
(901) 322-8195 – Fax (407) 487-7135 – Fax

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FAA Airport Solar Guide Appendix A. FAA Contact Information

Southwest Region
(Arkansas, Louisiana, New Mexico,
Oklahoma, Texas)

Federal Aviation Administration

Airports Division, ASW-600
10101 Hillwood Parkway
Fort Worth, TX 76117
(817) 222-5600 – Tel.
(817) 222-5987 – Fax

Arkansas/Oklahoma Airport Development Louisiana/New Mexico Airport Development

Office Office
(Arkansas, Oklahoma) (Louisiana, New Mexico)

Federal Aviation Administration Federal Aviation Administration

Arkansas/Oklahoma District Office Louisiana/New Mexico Airport District Office
(ASW-630) (ASW-640)
10101 Hillwood Parkway 10101 Hillwood Parkway
Fort Worth, TX 76117 Fort Worth, TX 76117
(817) 222-5630 – Tel. (817) 222-5640 – Tel.
(817) 222-5984 – Fax (817) 222-5984 – Fax

Texas Airport Development Office

(Texas)

Federal Aviation Administration

Texas Airports District Office (ASW-650)
10101 Hillwood Parkway
Fort Worth, TX 76117
(817) 222-5650 – Tel.
(817) 222-5987 – Fax

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 FAA Airport Solar Guide Appendix A. FAA Contact Information

Western-Pacific Region
(Arizona, California, Hawaii, Nevada, Guam,
American Samoa, Marshall Islands)

Federal Aviation Administration

Airports Division, AWP-600
15000 Aviation Boulevard
Room 3012
Lawndale, CA 90261
(310) 725-3600 – Tel.
(310) 725-6847 – Fax

Physical Address:
15000 Aviation Boulevard, Room 3012
Lawndale, CA 90261

Honolulu Airports District Office Los Angeles Airports District Office

(Hawaii, Guam, American Samoa, Marshall Islands) (Southern California)

Federal Aviation Administration Federal Aviation Administration

Honolulu Airports District Office Los Angeles Airports District Office
P.O. Box 50244 15000 Aviation Boulevard
Honolulu, HI 96850-0001 Room 3024
(808) 312-6028 – Tel. Lawndale, California 90261
(808) 312-6048 – Fax (310) 725-3644 – Tel.
(310) 725-3608 – Fax
Physical Address:
300 Ala Moana Blvd, Rm 7-128 San Francisco Airports District Office
Honolulu, HI 96850-0001 (Northern California)

Phoenix Airports District Office Federal Aviation Administration

(Nevada, Arizona) San Francisco Airports District Office
1000 Marina Blvd, Suite 220
2800 N Central Avenue Brisbane, CA 94005-1835
Suite 1025, 10th Floor
(650) 827-7600 – Tel.
Phoenix, AZ 85012
(602) 792-1060 – Tel. (650) 827-7634 – Fax
(602) 792-1061 - Fax

FAA Technical Center

FAA William J Hughes Technical Center

FAA Airport Technical R & D Branch
ANG-E261 Building 300
Atlantic City, NJ 08405
Tel. 609-485- 8032
Fax 609-485-4569
http://www.airporttech.tc.faa.gov/

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FAA Solar Guide Appendix B. Existing Solar Projects

Appendix B. Existing Airport Solar

Projects and Contacts

B-1
 FAA Solar Guide Appendix B. Existing Solar Projects

FAA Solar Guide

Solar Projects
Airport Facility Location Size Owner Contact Position Address City Phone Email
Type Name
Albuquerque Roof Carport Roofs 146 kW Airport Jim Hinde Director PO Box Albuquerque, 505-244- Jhinde@cabq.gov
Sunport 9948 NM 87119 7805
Bakersfield Ground Between Terminal 748 kW Private Jack Gotcher Aviation 3701 Wings Bakersfield, 661-393- airports@lightspeed.net
Meadows Field and Runway Developer Director Way CA 93308 1870
Boston Logan Roof Parking Garage B 200 kW Massport Terry Civic Utilities One Boston, MA (617) 568- TCivic@massport.com
Manager Harborside 02128 5996
Drive, Ste.
200S
Denver Ground Entrance Road 2.0 MW, Private Woods Allee Budget 8500 Pena Denver, CO (303) 342- Woods.Allee@flydenver.com
(2) Fuel Farm 1.6 MW Developer Liaison Boulevard 80249 2632

Fresno Yosemite Ground Runway End 2 MW Private Kevin Airport 4995 E Fresno, CA 559-621- Kevin.Meikle@fresno.gov
Developer Meikle Planner Clinton 93427 4536
Way
Houston George Roof Terminal Rooftop 60 kW Airport James Parise EMS 16930 John Houston, TX 281-233- jim.parise@cityofhouston.net
Bush Manager F. Kennedy 77032 1756
Blvd.
Oakland Ground General Aviation 756 kW Private Anthony Port of 530 Water Oakland, 510-627- akekulawela@portoakland.com
Area Developer Kekulawela Oakland Street CA 94607 1647

San Francisco Roof Terminal 3 500 kW SF Public Greg Project PO Box San Francisco, 650-821- Greg.McCarthy@flysfo.com

Appendix B. Existing Solar Projects

Utility McCarthy Engineer 8097 CA 94128 5304

San Jose Roof Rental Car Facility 1.1 MW Airport Dave Maas Deputy 1732 North San Jose, CA 408-392- dmaas@sjc.org
Director First St. 95112 3630
Aviation
*Projects are also located at Austin TX, Burbank CA, Long Beach CA, Prescott AZ, and five airports in Hawaii.
B-2
FAA Solar Guide Appendix C. Private Developer Ground Lease

Appendix C. Private Developer

Ground Lease Example (Denver)

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FAA Solar Guide Appendix C. Private Developer Ground Lease

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FAA Solar Guide Appendix C. Private Developer Ground Lease

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FAA Solar Guide Appendix C. Private Developer Ground Lease

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FAA Solar Guide Appendix D. Power Purchase Agreement Example

Appendix D. Power Purchase

Agreement Example (Denver)

D-1
FAA Solar Guide Appendix D. Power Purchase Agreement Example

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FAA Solar Guide Appendix D. Power Purchase Agreement Example

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FAA Solar Guide Appendix D. Power Purchase Agreement Example

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FAA Solar Guide Appendix D. Power Purchase Agreement Example

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