FAA Solar Glare Policy

What the 2021 Policy Changed

The FAA's Final Policy on Review of Solar Energy System Projects on Federally-Obligated Airports (Doc. 2021-09862) took effect on May 11, 2021, replacing the 2013 Interim Policy (Doc. 2013-24729). Much of the glare guidance still circulating describes the 2013 rules. Four provisions changed.

Analysis results are no longer submitted

“Airport sponsors are no longer required to submit the results of an ocular analysis to FAA.” There is no FAA glare review and no FAA determination on glare to obtain.

The sponsor certifies on Form 7460-1

The sponsor includes “a statement in its completed Form 7460-1 that the proposed solar project will not result in ocular (i.e. glint or glare) impacts to the airport's ATCT cab.” The FAA relies on that statement.

No analysis tool is specified

“FAA is also withdrawing the recommended tool for ocular impact, the Solar Glare Hazard Analysis Tool (SGHAT).” The 2013 policy required SGHAT and considered alternatives case by case. The current policy names no tool, sets no numerical threshold, and prescribes no method.

Final approach is no longer covered

The 2013 policy set a standard along final approach, defined as two miles out from fifty feet above the landing threshold on a three-degree glidepath. The FAA “has subsequently concluded that in most cases, the glint and glare from solar energy systems to pilots on final approach is similar to glint and glare pilots routinely experience from water bodies.” The tower cab is the only receptor named in current policy.

The analysis did not become optional

The 2021 policy moved the determination from the FAA to the airport sponsor. Someone at the airport signs a statement that a proposed project will not cause glare in the tower cab, without an FAA-specified method to reference and without an FAA review standing behind the conclusion. The obligation to get the answer right did not change; the party carrying it did.

Which Projects the Policy Covers

The policy applies to “proposed on-airport solar energy systems at federally-obligated towered airports.” All three conditions must hold. Most projects that need a glare study fall outside it, which does not mean no one is asking for one.

Project	FAA solar policy	In practice
On a federally-obligated airport with a control tower	Applies	Analyze the tower cab, then certify on the Form 7460-1. Many airports ask to see the analysis itself before the sponsor signs.
On an airport without a control tower	Does not apply	Airport management, funding conditions, and local permitting commonly require a glare study regardless.
Off-airport, near an airport or under a flight path	Does not apply	The most common case for a glare study. Airport operators, planning authorities, and project objectors request them routinely. Obstruction notice requirements may apply separately on height.
Not near an airport	Does not apply	Highways, railways, residences, and neighboring property drive these requests, under state, local, or national rules rather than FAA policy.

Requirements Outside FAA Policy

The 2013 interim policy became the reference document for glare requirements well beyond the United States. Several national authorities adopted its structure, and a number of them go further than the FAA ever did: some require departure paths as well as approach paths, and some specify custom flight tracks for the analysis, including curved or non-standard approaches at a particular airport. A project that satisfies current FAA policy is not automatically sufficient elsewhere.

Criteria also differ in kind. EASA guidance material on solar panel glare specifies a maximum acceptable luminance of 20,000 cd/m² (GM1 ADR-DSN.M.615 General (k)(2)), which is a different measurement from the ocular impact categories used in the SGHAT methodology. ForgeSolar reports luminance alongside ocular impact so both criteria can be addressed from one analysis; see the help guide for how the two relate.

Flight path glare remains a live risk

The FAA's conclusion concerns the typical case. The consequences in the atypical case are severe, and recent. In March 2025 glare from a solar park beneath the approach paths to the Polderbaan and Zwanenburgbaan runways at Amsterdam Airport Schiphol led to restrictions on arriving traffic in sunny conditions, including a period in which the Polderbaan was closed to arrivals between 10:00 and 12:00. The airport, the park operator, the municipality of Haarlemmermeer, and the Dutch Ministry of Infrastructure and Water Management agreed in August 2025 on a remedy: dismantle the affected panels, apply an anti-reflective film, and reinstall them. Work began on 78,000 panels across two of the park's four fields, with the approach assessed by independent parties and by the sector's Integral Safety Management System.

The park was off-airport and would not have been covered by FAA solar policy had it been in the USA. The remedy was also a retrofit of installed hardware, which is the expensive point at which to discover glare. Where approach or departure paths are plausibly affected, they are worth analyzing whether or not a policy compels it. Schiphol's statement on the agreed solution sets out the arrangements.

What a Glare Analysis Should Include

With no method prescribed, the standard of care falls to whoever signs. The parameters below are the ones the FAA specified while it did prescribe a method, and they remain the working benchmark among practitioners and reviewing authorities.

Analysis checklist

The tower cab at its actual geometry
The receptor named in current policy. Model the cab's real height and position rather than the airport reference point.
A full calendar year at one-minute intervals
Sunrise to sunset, as required under the 2013 policy. Coarser sampling can miss the weeks in which the geometry aligns.
Approach paths, and departure paths where required
Outside current FAA policy but frequently requested, and mandatory under several non-US policies. The FAA definition was two miles out from fifty feet above the landing threshold on a three-degree glidepath; custom flight tracks can be analyzed where an authority specifies them.
Ocular impact classification, and luminance where relevant
Not only whether glare occurs, but its predicted effect: low potential for after-image, potential for after-image, or potential for retinal damage. Luminance is the criterion used in EASA guidance.
The inputs behind the result
Array geometry, module surface characteristics, receptor positions, and analysis period. A certification is only as good as the inputs it rests on.
A report retained on file
Nothing is sent to the FAA, so the analysis serves as the sponsor's own record supporting the statement, and as the document an airport or planning authority will ask to see.

How to evaluate a glare analysis tool covers the related question of what to ask of the software producing the numbers.

Glare Classifications

Current FAA policy sets no numerical threshold and publishes no acceptability table. These are the categories an analysis produces and how the 2013 standard treated them, which remains the reference point most reviewers reason from.

Classification	Predicted effect	Under the 2013 standard
Low potential for after-image	Glare occurs but is not predicted to produce a temporary after-image.	Permitted along final approach. Not permitted at the tower cab, where the standard was no potential for glint or glare at all.
Potential for after-image	Sufficient intensity to produce a temporary after-image.	Failed the standard at either receptor. Usually addressed by adjusting tilt, orientation, layout, or module surface.
Potential for retinal damage	Sufficient intensity to risk permanent injury. Rare for photovoltaic modules.	Failed the standard wherever predicted.

The Current Process

1

Analyze

Run the analysis before the Form 7460-1 is filed, while the design can still be adjusted at low cost.

2

Certify

The sponsor states on the Form 7460-1 that the project will not cause ocular impact to the tower cab. No analysis is attached and none is reviewed by the FAA.

3

Retain

Keep the analysis on file. It is the supporting evidence if the project is questioned later, and what airports and planning authorities ask to see.

Where ForgeSolar Fits

The method FAA policy prescribed

ForgeSolar implements the SGHAT methodology, which FAA policy required by name from 2013 until 2021 and which underpins hundreds of analyses accepted in FAA review. The methodology is unchanged and published; the agency simply no longer designates any tool.

Receptors beyond the tower cab

Approach and departure paths, custom flight tracks, roads, railways, and observation points, with luminance reported alongside ocular impact. The requirements outside FAA policy are usually the broader ones.

Design changes when glare is predicted

GlaReduce searches tilt and orientation for layouts that avoid glare on sensitive receptors while preserving energy yield, so a finding at design stage results in a revised layout rather than an abandoned site.

Support from the method's authors

Direct assistance from the team that co-developed SGHAT, plus professional review when a sponsor or authority wants an independent assessment on the record.

This page summarizes published FAA policy for general guidance and is not legal advice. Policy changes: confirm the current position against the 2021 Final Policy and with the authority reviewing your project. Both FAA policies are listed in our references.

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