A public-use airport (TSO) is documented about 5 miles southeast (C-22ecd9258b), and low-potential green glare is predicted at two residences and a short segment of Linnet Road (C-1a3c29d782, C-3a488792dd). Contrary absence findings (no yellow/red glare, no TSO approach glare, no microwave path, no private airstrip, no military/radar) cover different receptors and are consistent with this (C-06d00931f7, C-7fb4ed5f9f, C-cf1066cd5b, C-47b8505413, C-4c304fc268).
All structures are over 20,000 feet from the nearest runway, no protected surface is penetrated (C-698d47b3cd, C-7ae4ad619f), no microwave path crosses the area (C-cf1066cd5b). Only low-potential glare at a few receptors remains (C-1a3c29d782).
No yellow or red glare is predicted (C-06d00931f7); the green glare is minor and no airport surface is affected (C-7ae4ad619f). Layout, tilt or screening can address any residual issue.
No FAA Form 7460-1 notice is required, as structures are beyond 20,000 feet of the runway and under 200 feet (C-698d47b3cd). The ODOT Office of Aviation permit does not apply to an OPSB-certificated facility (C-8022ac270d, OH-AIRPORT). The glare study is already complete.
No glare at TSO approaches, no hazard to airspace, and only low-potential green glare at two residences and a short road segment of limited duration (C-7fb4ed5f9f, C-1a3c29d782, C-3a488792dd). A hazard determination or redesign is not likely.
Nearest public-use airport (TSO) is about 5 miles southeast. Structures are over 20,000 feet from the runway and under 200 feet, so no FAA Form 7460-1 notice is required. Low-potential (green) glare predicted at two residences and a short segment of Linnet Road; no glare at TSO approaches.
Critique
Verdict
upheld
Suggested direction for the rating
same
Summary
Assessment is well supported by the cited quotes. Category 1 follows from low-potential green glare, no Part 77 notice, and no airspace penetration. Only minor wording issues: the unsupported "glare study complete" line and unclear agency roles.
Critic model
Luminol
Issues
Severity minor · Kind unsupported_statement
The pathway rationale says "The glare study is already complete." No cited quote says this. The glare findings come from DR-0015, but that document's completeness or scope is not stated. Cite the study or soften the wording.
The pathway is "none", but the agencies list FAA and OPSB. The OPSB role is that the Ohio Office of Aviation consults it, and the project's certificate status is not evidenced. The worst case uses "pathway standard" without naming the step. Clarify the agencies' roles.
No yellow or red glare is predicted at any receptor.
Quote check Exact · Placed verbatim · The quote occurs on the page exactly as written. · Read as native
Parhelion Analytics, LLC
Glare, aviation and visual studies for energy projects | Cleveland, Ohio
Glare, Aviation and Visual Memo
To: Northfold Energy Partners, LLC. From: Parhelion Analytics. April 25, 2023.
Re: Tamsin Ridge Solar and Storage Project, Carroll County, Ohio.
1. Airports and airspace
The nearest public-use airport is Carroll County-Tolson Airport (TSO), about 5 miles southeast of the Project. No
private airstrip or heliport is within 3 miles. The tallest proposed structures are the gen-tie poles (up to 85 feet),
the substation dead-end structures (65 feet) and the lightning masts (70 feet); modules on trackers are under 12
feet.
We screened the structures against the FAA notice criteria of 14 CFR Part 77 (Section 77.9). Every structure is
more than 20,000 feet from the nearest runway and none exceeds 200 feet above ground, so no FAA Form
7460-1 notice is required. The Ohio Department of Transportation Office of Aviation permit does not apply to a
facility certificated by the OPSB, and no protected airport surface is penetrated in any case.
Microwave and radar. A search of FCC licensing records found no licensed microwave beam path across the
Project Area. No military operations area or radar installation is nearby.
2. Glare analysis
Glare was modeled with the Solar Glare Hazard Analysis Tool (SGHAT) method for single-axis trackers with
backtracking and a 60-degree maximum tilt, using the draft layout. Receptors: the two runway approach paths at
TSO, 18 observation points on State Route 43, Linnet Road and Fescue Road, and the 23 residences within
1,000 feet.
• TSO approaches: no glare predicted.
• Roads: no glare predicted for drivers on State Route 43 or Fescue Road; low-potential (green) glare for under
10 minutes on a few days a year on a short segment of Linnet Road.
• Residences: low-potential (green) glare at two residences (R-11 and R-14) for 5 to 15 minutes on spring and
autumn mornings. Quote starts. No yellow or red glare at any receptor. Quote ends.
The glare at R-11 and R-14 disappears behind the screening plantings proposed below once they reach about 8
feet in height.
Parhelion Analytics, LLC Page 1 of 2
The outline marks where the quote begins on the page.
C-06d00931f7
No yellow or red glare is predicted at any receptor.
The requirements the assessor tied to this row, by level. Each quote from dated law is shown with its source.
Federal
Form 7460-1 Notice of Proposed Construction or Alteration
F-FAA77 · Federal Aviation Administration
Applicability
Conditional
Instrument
14 CFR Part 77
Trigger
Structures or cranes meeting notice criteria near airports or over 200 feet above ground.
Description
Notice for construction that meets Part 77 notice criteria (for example structures over 200 feet, or within defined distances and slopes of public-use airports). FAA's 2021 glare policy covers solar on federally obligated airports, not off-airport projects.
Typical timeline
Notice on Form 7460-1 at least 45 days before the start date of construction or the date a construction-permit application is filed, whichever is earliest (14 CFR 77.7(b)); Part 77 sets no FAA decision deadline. A Determination of No Hazard expires 18 months after its effective date unless extended (14 CFR 77.33(b)). Typical: 2 to 4 months for an FAA aeronautical study determination (basis: practice, not stated in the sources).
As of the cut-off
As of the cut-off: FAA published its interim policy on solar energy systems at federally obligated airports (78 FR 63276). (2013-10-23) FAA's policy on solar energy system projects at federally obligated airports took effect (86 FR 25801), replacing the 2013 interim policy; it covers on-airport systems at towered airports. (2021-05-11)
If requested by the FAA, or if you propose any of the following types of construction or alteration, you must file notice with the FAA of: (a) Any construction or alteration that is more than 200 ft. AGL at its site. (b) Any construction or alteration that exceeds an imaginary surface extending outward and upward
Source 14CFR77 · page 1 · version 2023-08-01
Cited for requirement and trigger
In force from 2016-12-30 to 2026-10-07
eCFR versioner: 14 CFR part 77, same text on 2021-10-15, 2022-05-20, 2022-09-12, 2023-04-22, 2023-08-01 and on every amendment date between them; amendment dates 2016-12-30
May be cited on the cut-off date.
Quoted from the law, page 1
a completed FAA Form 7460-1, Notice of Proposed Construction or Alteration. FAA Form 7460-1 is available at FAA regional offices and on the Internet. (b) You must submit this form at least 45 days before the start date of the proposed construction or alteration or the date an application for a construction permit is filed, whichever is earliest.
Source 14CFR77 · page 1 · version 2023-08-01
Cited for requirement (Form 7460-1) and timeline: 45-day notice
In force from 2016-12-30 to 2026-10-07
eCFR versioner: 14 CFR part 77, same text on 2021-10-15, 2022-05-20, 2022-09-12, 2023-04-22, 2023-08-01 and on every amendment date between them; amendment dates 2016-12-30
May be cited on the cut-off date.
Quoted from the law, page 1
Unless extended, revised, or terminated, each Determination of No Hazard to Air Navigation issued under this subpart expires 18 months after the effective date of the determination, or on the date the proposed construction or alteration is abandoned, whichever is earlier.
Source 14CFR77 · page 1 · version 2023-08-01
Cited for timeline: validity of a determination
In force from 2016-12-30 to 2026-10-07
eCFR versioner: 14 CFR part 77, same text on 2021-10-15, 2022-05-20, 2022-09-12, 2023-04-22, 2023-08-01 and on every amendment date between them; amendment dates 2016-12-30
May be cited on the cut-off date.
Quoted from the law, page 1
The policy applies to proposed on-airport solar energy systems at federally-obligated towered
Source 86FR25801 · page 1 · version 2021-05-11
May be cited on the cut-off date.
State
ODOT Office of Aviation permit for a structure that may obstruct air navigation near an airport; not required for a facility holding an OPSB certificate, which is reviewed through the OPSB process
OH-AIRPORT · Ohio Department of Transportation (ODOT), Office of Aviation (permit); Ohio Power Siting Board (OPSB) (certificated facilities, after consulting the Office of Aviation)
Applicability
Conditional
Instrument
ORC 4561.30 to 4561.39 (Ohio Airport Protection Act); ORC 4561.341; ORC 4906.10(A)(5)
Trigger
A structure or object of natural growth that will penetrate, or is reasonably expected to penetrate, a protected surface of an airport open to the public, for a project that has not received an OPSB certificate.
Description
No person may begin to install a structure or object of natural growth, any part of which will or is reasonably expected to penetrate an airport's clear zone, horizontal, conical, primary, approach or transitional surface, without an ODOT permit. "Airport" means one certified for commercial purposes by ODOT; ODOT's guidance applies the permit to airports open to the public, and a filed FAA Form 7460-1 meets the state application requirement. ODOT grants or denies the permit by deciding whether the height and location would obstruct air navigation. A person who receives an OPSB certificate is not required to apply. Instead, if the Office of Aviation finds an obstruction, it gives the OPSB that determination in writing with either the conditions needed to remove it or a statement that compliance may be waived, and the OPSB must consult the Office.
Typical timeline
File not less than thirty days nor more than two years before the planned start of installation; the department may waive this period for unforeseen emergencies (ORC 4561.33(B)).
no person shall commence to install any structure or object of natural growth in this state, any part of which will penetrate or is reasonably expected to penetrate into or through any airport's clear zone surface, horizontal surface, conical surface, primary surface, approach surface, or transitional surface without first obtaining a permit from the department of transportation
Source ORC 4561.30 to 4561.39 airport obstructions · page 2 · version 2023-08-01
In force from 2004-01-01 to 2026-10-03, section 4561.31
4561.31: version effective 2004-01-01, still the current version when the page map was checked (2026-10-03)
May be cited on the cut-off date.
Quoted from the law, page 3
Any person who receives a certificate from the power siting board pursuant to section 4906.03 or 4906.10 of the Revised Code on or after October 15, 1991, is not required to apply for a permit from the department under sections 4561.30 to 4561.39 of the Revised Code.
Source ORC 4561.30 to 4561.39 airport obstructions · page 3 · version 2023-08-01
In force from 2004-01-01 to 2026-10-03, section 4561.31
4561.31: version effective 2004-01-01, still the current version when the page map was checked (2026-10-03)
May be cited on the cut-off date.
Quoted from the law, page 1
"Airport" means any airport certified for commercial purposes by the department of transportation. "Airport" does not include a military airport owned by the United States government and used for no commercial purposes.
Source ORC 4561.30 to 4561.39 airport obstructions · page 1 · version 2023-08-01
In force from 1991-10-15 to 2026-10-03, section 4561.30
4561.30: version effective 1991-10-15, still the current version when the page map was checked (2026-10-03)
May be cited on the cut-off date.
Quoted from the law, page 6
An applicant shall file an application not less than thirty days nor more than two years prior to the planned date of commencement of installation or substantial change. This period may be waived by the department for unforeseen emergencies.
Source ORC 4561.30 to 4561.39 airport obstructions · page 6 · version 2023-08-01
In force from 1991-10-15 to 2026-10-03, section 4561.33
4561.33: version effective 1991-10-15, still the current version when the page map was checked (2026-10-03)
May be cited on the cut-off date.
Quoted from the law, page 8
In determining whether to grant or deny a permit, the department shall determine whether the height and location of a structure or object of natural growth, as set forth in the permit application, will be an obstruction to air navigation based upon the rules adopted under section 4561.32 of the Revised Code if installed as proposed.
Source ORC 4561.30 to 4561.39 airport obstructions · page 8 · version 2023-08-01
In force from 1991-10-15 to 2026-10-03, section 4561.34
4561.34: version effective 1991-10-15, still the current version when the page map was checked (2026-10-03)
May be cited on the cut-off date.
Quoted from the law, page 14
if the office determines that the facility constitutes or will constitute an obstruction to air navigation, it shall provide, in writing, this determination and either the terms, conditions, and modifications that are necessary for the applicant to eliminate the obstruction or a statement that compliance with the obstruction standards may be waived, to the power siting board
Source ORC 4561.30 to 4561.39 airport obstructions · page 14 · version 2023-08-01
In force from 1999-06-30 to 2026-10-03, section 4561.341
4561.341: version effective 1999-06-30, still the current version when the page map was checked (2026-10-03)
May be cited on the cut-off date.
Quoted from the law, page 17
determining whether the facility will comply with all rules and standards adopted under section 4561.32 of the Revised Code, the board shall consult with the office of aviation of the division of multi-modal planning and programs of the department of transportation under section 4561.341 of the Revised Code.
Source ORC 4906 Power Siting Board · page 17 · version 2023-08-01
In force from 2021-10-11 to 2025-08-13, section 4906.10
4906.10: version effective 2021-10-11; first change after it 2025-08-14 (Am. Sub. H.B. 15, 136th GA), from codes.ohio.gov version history in archive captures (confirmed_two_sources)
May be cited on the cut-off date.
Quoted from the law, page 1
Additionally, a permit from the Ohio Department of Transportation's Office of Aviation must be obtained prior to the start of any construction on or near airports in Ohio that are open to the public. Filing the 7460-1 with the FAA above fulfills the state permit application requirements as set forth in the Ohio Administrative Code, Section 5501:1.
Source ODOT Office of Aviation airport protection act page · page 1 · version 2022-07-28
May be cited on the cut-off date.
Information requests
No information request for this row.
Next steps
Re-run glare analysis if the layout or module tilt changes.
Confirm no FAA notice is needed against final structure heights and crane use.
Agencies
FAA
OPSB
Cost and impact
Impact
None given.
Potential cost level
N/A
Why
No notice, permit or redesign is required, so no material cost or schedule exposure is identified.
Impact: C = cost, S = schedule. Potential cost level: L, L-M, M, M-H, H (relative to a utility-scale solar budget).
Comments
Nearest public-use airport (TSO) is about 5 miles southeast. Structures are over 20,000 feet from the runway and under 200 feet, so no FAA Form 7460-1 notice is required. Low-potential (green) glare predicted at two residences and a short segment of Linnet Road; no glare at TSO approaches.