Aviation glint and glare: South Africa and the FAA

Audience: project owners, EPCs, airport stakeholders, reviewers
Date Created: 10 August 2026
Revised: 11 August 2026 — ATNS / CAR Part 178 approval path added
Status: client information – not legal advice – to be read in conjunction with the PQRS G&G report Methodology

Purpose of this note

Photovoltaic (PV) arrays can reflect sunlight toward people and aviation observers. In the United States, the Federal Aviation Administration (FAA) has published a clear pass/fail test for air traffic control towers.

South African documentation is usually framed around obstacle / aerodrome safety, environmental screening distances, and Civil Aviation Regulations on glare and obstacles.

Who approves in South Africa: SACAA no longer assesses obstacle applications in-house. Under CAR Part 178, approved obstacle-assessment service providers do the assessment; SACAA oversees. Other Part 178 holders appear on the current SACAA obstacles list (caa.co.za/industry-information/obstacles).

This note summarises how the two guidelines differ, and how PQRS reports should be read on South African projects. It is informational. Even though it complies with FAA Rules it does not replace ATNS (or another CAR Part 178 holder) assessment, SACAA oversight, DFFE, or airport-operator requirements. A PQRS report is not a SACAA or ATNS approval, but it does form part of the application process towards approval.

The short version

TopicUnited States (FAA)South Africa
Who reviewsFAA (on-airport / federally obligated)ATNS (or another CAR Part 178 holder) assesses; SACAA oversees. Applications are not lodged with SACAA for assessment.
Primary aviation test2021 FAA policy: no glare of concern at the Air Traffic Control Tower (ATCT) cabNo FAA-style ATCT pass/fail in SACAA policy. Obstacle Notice 3/2020 requires a Glint & Glare Impact Assessment for named geometry. ATNS also consider tower line of sight and solar glare in Annex 14 obstacle work.
Flight-path colour (green / yellow / red)2013 interim policy. 2021 policy treats 2-mile approach-path colour as no longer required for FAA reviewStill commonly requested in SA / ATNS packs because reviewers know the 2013-shaped output
Off-airport “study radius”FAA does not set a km radius around the airport. The old “2 miles” is approach-path geometry, not a circle around the fenceSACAA Obstacle Notice 3/2020: 3 km of the aerodrome / helistop, plus ICAO approach, take-off climb and departure surfaces (OLS often extend well beyond 3 km).
Environmental screeningNot the FAA’s roleDFFE GN 320 (GG 43110): aviation consultation typically 8 km (non-military) / 35 km (military) of a PV facility
Lights / glare at aerodromesFAA policy on solar glare at ATCTCAR 139.01.10 — lights that may cause glare or confusion
ObstaclesSeparate FAA obstruction rulesCAR 139.01.30 and Obstacle Notice 3/2020, assessed by ATNS / Part 178 providers

PQRS simulation rule: the FAA 2021 ATCT result is the aviation PASS / FAIL. The 2013 flight-path colour chart is informational (still useful for SA reviewers). Multi-array sites use the worst hazard in each minute across arrays. On South African jobs the report is lodged with ATNS (or the appointed Part 178 provider) as a specialist study — it is not the approval.

United States — FAA

2013 interim policy (still widely recognised)

The 2013 FAA interim policy for on-airport solar asked proponents to show, using a tool of the SGHAT type:

  • no potential for glare at the ATCT; and
  • along the final approach path for any existing or proposed landing runway, within 2 miles of that path, glare of low potential for after-image (“green”) only — not yellow or red.

That is why many reports still print a green / yellow / red approach-path chart. It is a 2013-era presentation, not the current FAA review test.

2021 FAA policy (current US review)

The October 2021 FAA policy revision is the current US position for on-airport solar:

  • The only required ocular-impact demonstration is no glare of concern at the ATCT.
  • The 2-mile final-approach-path colour analysis is no longer required for FAA review.
  • FAA did not introduce a “study everything within X km of the airport” radius. Distance is driven by whether the array can put glare on the tower (and, if you still model it, the approach path).

2 miles in the 2013 text is the length of the final approach path being assessed, not a circle drawn around the aerodrome boundary. Treating it as a 3.2 km buffer around the airport is a common incorrect assumption.

South Africa

South Africa has no published SACAA circular that adopts FAA 2021 ATCT pass/fail as the national solar-glare test. It does require a Glint & Glare Impact Assessment in defined Notice 3/2020 cases. Obstacle / aviation safety applications are assessed by ATNS (and other CAR Part 178 holders); SACAA oversees and no longer accepts those applications for assessment. The remaining justification usually comes from four overlapping sources.

1. Who assesses — SACAA, ATNS, and CAR Part 178

SACAA has advised that obstacle applications are no longer accepted by the Authority for assessment. Under Civil Aviation Regulations Part 178, approved obstacle-assessment service providers perform the assessments. SACAA’s role is oversight of those holders. ATNS conduct Annex 14 obstacle assessments and, in that process, consider protection of ATC tower line of sight and glint and glare from solar panels. PQRS produces the specialist glint and glare report that the proponent lodges with ATNS / the Part 178 provider. PQRS does not issue the aviation approval.

2. SACAA Obstacle Notice 3/2020 (aerodrome / obstacle / glint and glare)

Obstacle Notice 3/2020 (effective 1 June 2020) replaced Obstacle Notice 4/2017. It tells proponents when an obstacle application is needed, and when a Glint & Glare Impact Assessment must accompany a solar application. In summary, an obstacle application is needed for:

  • structures 3 km or closer to an aerodrome; and/or
  • structures that penetrate ICAO Annex 14 approach or take-off climb (TOCS) surfaces,

require assessment / application to an approved CAR Part 178 obstacle-assessment provider (typically ATNS; [email protected]), with surveyor coordinates and elevations. SACAA does not assess these applications in-house.

For PV, this is the usual trigger for aviation consultation: not “FAA 2 miles”, but 3 km + OLS / approach / TOCS (and helistops). SACAA also stated that a Glint & Glare Assessment is required when the site is on the extended runway centreline within the ICAO Annex 14 Approach, Take-Off Climb and Departure surfaces, and within a 3 km radius of an aerodrome or helistop (CAR 139.01.30(3)). A site outside 3 km can still need G&G if it sits under those surfaces (OLS often extend on the order of 15 km from the aerodrome reference point). A hospital helipad counts as a helistop. Glint and glare is supporting evidence for ATNS / Part 178 review and cannot really be considered a substitute for the obstacle application itself, and it is not a SACAA certificate.

3. DFFE screening (environmental process)

Government Notice 320 of 20 March 2020 (Government Gazette 43110) sets site-sensitivity screening procedures under NEMA. For a PV facility, the aviation protocol typically requires the proponent to consult the Civil Aviation Authority where the site is within:

  • 8 km of a civil aviation facility, or
  • 35 km of a military aviation facility.

That is a consultation / sensitivity distance in the environmental process. It is not the same as the SACAA 3 km obstacle notice, and it is not an FAA radius.

4. Civil Aviation Regulations (glare and obstacles)

Two CAR provisions should be noted:

  • CAR 139.01.10 — Lights. A person must not endanger an aircraft by shining a light (or causing a light to be shone) so as to dazzle or distract the pilot, or so as to be mistaken for an aeronautical ground light. Reflected sunlight is not a “light fitting”, but the policy intent (no confusing or dazzling light toward aircraft / the aerodrome) is why glare assessments are requested.
  • CAR 139.01.30 — Obstacles. Addresses obstacles in the vicinity of aerodromes (height, marking, lighting, permission). Solar tables are usually treated as structures / obstacles first; glare is the visual companion issue.

CAR Part 178. Approval of organisations that assess obstacle applications (ATNS and others listed by SACAA).

ICAO Annex 14 Volume I (aerodrome design) underpins the OLS / approach / TOCS geometry used in Notice 3/2020. ICAO does not publish a solar-glare pass/fail equivalent to FAA 2021.

How PQRS applies this on a South African project

  1. Geometry first. Identify aerodromes and helistops, runways, ATCT (if any), and whether the array sits inside 3 km, extended centreline / OLS / approach / TOCS / departure, and/or the DFFE 8 km / 35 km screening rings.

Approval path. Write the report for lodging with ATNS (or the Part 178 holder the client names).

  • ATCT (FAA 2021). If a control tower is a receptor, the PQRS aviation PASS/FAIL is the 2021-style ATCT result: glare of concern at the cab is a fail.
  • Flight-path colour (2013). Still produced as informational output. SA reviewers often expect a green / yellow / red approach chart even though FAA no longer requires it for US review.
  • Combined site. Where several arrays are modelled, the site result for each minute is the worst hazard among arrays (not an average).
  • Roads and dwellings. Reported separately. They are not the FAA ATCT test and are not a SACAA obstacle determination.
  • Authority process. Obstacle applications are assessed by ATNS (or another Part 178 holder). DFFE consultation and airport-operator conditions remain outside the software.
    The PQRS G&G report is evidence for those processes, not the approval.

Practical implications

  • Do not tell a SA reviewer that “FAA 2021 means we can skip approach-path charts.” Many SA files still want the 2013-shaped figure.
  • 2 miles should not be treated as a South African boundary and users can use Notice 3/2020 (3 km + surfaces) and GN 320 (8 / 35 km) as the distance language.
  • The PQRS G&G report is an engineering demonstration aligned with the internationally recognised FAA tower test, offered in support of SA obstacle and environmental consultation. We supply the study which ATNS / Part 178 will then assess.

Do not skip G&G only because the site is beyond 3 km. Check extended centreline and OLS, and any helistop (including a hospital helipad).

  • Lights that dazzle (CAR 139.01.10) and obstacles (CAR 139.01.30 / Notice 3/2020) are different legal parameters. A clean glare chart does not waive an obstacle application if the structure is inside 3 km or penetrates a surface, it provides a summary of how the glare will be perceived at that observation point.

Document references

A numbered list of source documents is maintained for the website. See Document references (companion page) or the list below.

  1. Federal Aviation Administration, Technical Guidance for Evaluating Selected Solar Technologies on Airports, November 2010 (and later updates). Background on on-airport solar.
  2. Federal Aviation Administration, Interim Policy, FAA Review of Solar Energy System Projects on Federally Obligated Airports, 78 Fed. Reg. 63276, 23 October 2013. ATCT + 2-mile final approach path; green / yellow / red.
  3. Federal Aviation Administration, Federal Aviation Administration Policy: Review of Solar Energy System Projects on Federally-Obligated Airports, 86 Fed. Reg. 25801, 11 May 2021 (policy in effect 5 October 2021). ATCT-only ocular demonstration; approach-path colour no longer required for FAA review.
  4. Ho, C.K., Ghanbari, C.M., Diver, R.B., and others. Sandia / SGHAT technical publications on ocular impact (glint and glare) methodology. PQRS calculations are inspired by this published method; they are not Sandia-licensed software outputs.
  5. South African Civil Aviation Authority, Obstacle Notice 3/2020, effective 1 June 2020 (replaces Notice 4/2017). Obstacle application and Glint & Glare Impact Assessment when on the extended centreline within Annex 14 approach / take-off climb / departure surfaces, and/or within 3 km of an aerodrome or helistop (CAR 139.01.30(3)).
  6. SACAA, CAR Part 178 / obstacles AIC — approved obstacle-assessment service providers. SACAA no longer accepts obstacle applications for assessment. ATNS ([email protected]) and other listed holders perform assessments. Live list: https://www.caa.co.za/industry-information/obstacles/
  7. ATNS, Annex 14 / aeronautical obstacle assessment (including ATC tower line of sight and solar glint and glare). Contact [email protected].
  8. Department of Forestry, Fisheries and the Environment, Government Notice 320, Government Gazette 43110, 20 March 2020. Procedures for site-sensitivity screening; aviation consultation typically 8 km (civil) / 35 km (military) of a PV facility.
  9. Civil Aviation Regulations, 139.01.10 — Lights (dazzle, distract, or confuse with aeronautical ground lights).
  10. Civil Aviation Regulations, 139.01.30 — Obstacles in the vicinity of aerodromes.
  11. ICAO, Annex 14 — Aerodromes, Volume I, Aerodrome Design and Operations (obstacle limitation surfaces, including approach and take-off climb).
  12. PQRS, Glint and Glare Assessment Methodology (site page / SITE_METHODOLOGY.md). Product narrative: engine version, assumptions, and limitations.

Disclaimer

This note is a working summary for PQRS simulation software and clients. Regulation and policy are amended from time to time. Always check the current FAA Federal Register text, SACAA notices, the live CAR Part 178 holder list, ATNS requirements, DFFE screening protocols, and the CAR as published.

PQRS does not provide legal advice and does not issue aviation approvals.