Aeronautical Assessment

2025-DOT-1020-OE / 2025-AGL-15824-OE
2025-DOT-1021-OE / 2025-AGL-15831-OE
2025-DOT-1022-OE / 2025-AGL-15832-OE
2025-DOT-1023-OE / 2025-AGL-15833-OE
2025-DOT-1024-OE / 2025-AGL-15834-OE

Site: Proposed Stadium

Prepared for: Ohio Department of Transportation
Date: September 18, 2025
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Parameters and Assumptions

The defined Subject Project, located in Cleveland, OH, will be analyzed to determine if a 1007-foot
Above Means Sea Level (AMSL) building would create an adverse impact on air navigation.

Project Parameters
Total
Latitude Longitude Ground AGL
DOT Study Number FAA Study Number AMSL
(N) (W) (ft) (ft)
(ft)
2025-DOT-1020-OE 2024-AGL-15824-OE 41-24-31.40 81-49-34.98 786 221 1007
2025-DOT-1021-OE 2024-AGL-15831-OE 41-24-32.06 81-49-44.02 789 218 1007
2025-DOT-1022-OE 2024-AGL-15832-OE 41-24-38.25 81-49-35.92 789 218 1007
2025-DOT-1023-OE 2024-AGL-15833-OE 41-24-30.74 81-49-25.95 791 216 1007
2025-DOT-1024-OE 2024-AGL-15834-OE 41-24-24.55 81-49-34.05 787 220 1007
Table 1: Project Location and Height Parameters

Project Statistics
The proposed site is located southeast of approach end of Runway 28 at Cleveland-Hopkins
International Airport (CLE) The closest point of the Subject Project is located approximately 1886 feet
perpendicular to the runway centerline extended of Runway 10/28 at CLE.

Analysis Criteria
The following criteria will be reviewed:

- VFR Traffic Pattern Airspace (TPA)

- Instrument Approach Procedures
- Instrument Departure Procedures
- Low Altitude Airways
- Radio Communication Link Propagation Paths
- Navigational Aids
- Proposed Runways
- Private Landing Facilities

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VFR Traffic Pattern Airspace (TPA)

Figure 1: TERPS® image: VFR Traffic Pattern Airspace (TPA) at CLE.

The VFR Traffic Pattern Airspace (TPA) consists of the VFR Horizontal Surface, VFR Conical Surface, VFR
Approach Surface, VFR Transitional Surface, Climb/Descent Area, and Cross-traffic Area. As shown in
Figure 1, the Project is located within the VFR Horizontal Surface.

Figure 2 on the following page shows the typical flight path of an aircraft within the VFR Traffic Pattern
on the south side of Runway 10/28. The proposed stadium is located outside of the VFR Approach and
Transitional Surfaces.

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Figure 2: TERPS® image: VFR Traffic Pattern Airspace (TPA) at CLE.

FAA Order 7400.2

The FAA conducts its review of proposed structures in accordance with FAA Order 7400.2. The most
recent version, FAA Order 7400.2R, states:

Section 6-3-8. EVALUATING EFFECT ON VFR OPERATIONS

[…]

d. AIRPORT AREAS − Consider the following when determining the effect of structures on VFR operafions
near airports:

1. Traffic Paftern Airspace − There are many variables that influence the establishment of airport
arrival and departure traffic flows. Structures in the traffic pattern airspace may adversely affect
air navigation by being a physical obstruction to air navigation or by distracting a pilot’s
attention during a critical phase of flight. The categories of aircraft using the airport determine
airport traffic paftern airspace dimensions. NOTE− Traffic Paftern Airspace is for both arrivals
and departures. The considerations and calculations must account for both. Although called
“approach” slope or surface, the intent is to ensure adequate airspace is provided, including
additional safety margins, for aircraft operations both during landing and taking off.
Consequently, this could be thought of as approach and departure slope/surface. This is not the
same and should not be confused with the IFR Departure Surface.

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(a) Traffic Paftern Airspace dimensions (See FIG 6−3−9). NOTE− Airspace dimensions are
defined in both lateral and vertical terms. Traffic pattern airspace, however, has no
vertical component (i.e., no altitude). Therefore, any structure, terrain, nature growth,
etc. within the lateral dimensions shown in FIG 6−3−9 is within this airspace, no mafter
the height.

(b) Within Traffic Paftern Airspace − A structure that exceeds a 14 CFR, part 77
obstruction standard and that exceeds any of the following heights is considered to
have an adverse effect and would have a substantial adverse effect if a significant
volume of VFR aeronaufical operafions are affected except as noted in paragraph 6−3−8
d.1.(f) and (g) (see FIG 6−3−10).

6−3−4. DETERMINING SIGNIFICANT VOLUME OF ACTIVITY

OEG determines the volume of VFR/IFR activity, which must be considered in order to determine a
significant volume of activity. Guidelines for significant volume of VFR activity would be, for example, if
one or more aeronautical operations per day would be affected. This may indicate regular and
continuing activity. Compressed geographical areas (that may include seasonal traffic) or other
concentrations of VFR activity may also indicate regular and continuing activity and may be considered
significant. This analysis is conducted by the OEG under the further study evaluation portion of the
aeronautical study process.

Evaluation
While the proposed stadium does exceed the VFR Horizontal Surface, it does not conflict with airspace
used for normal VFR operations. Any aircraft departing from or approaching the east end of Runway
10/28 would have ample lateral separation from the stadium. The FAA’s protection of the VFR Approach
and Transitional surfaces is intended to prevent obstructions from creating potentially hazardous
situations during high crosswind approaches/departures or in cases where the aircraft may make an
early or late turn and become misaligned to the runway centerline extended. The stadium is located
outside of the VFR Approach and Transitional surfaces as shown in Figure 2.

Further, typical procedures when operating within the VFR TPA keep the aircraft operating at or above
400 feet above runway elevation during all phases of flight except for the final approach/initial climb.

 Aircraft departing Runway 10 would remain within the lateral bounds of the VFR Approach
surface until an altitude of at least 400 feet above runway elevation before turning left or right.

 Aircraft landing on Runway 28 would remain at the traffic pattern altitude of 1000 feet above
airport elevation until the aircraft is abeam the runway end. From this point, the pilot would
start their descent, eventually making a downwind-to-base leg turn and a base-to-final turn.
The final turn occurs while the aircraft is typically 500 feet above runway elevation, plus or
minus 100 feet. From this point, the aircraft aligns with the runway and remains within the
lateral bounds of the VFR Approach Surface while descending until it touches down.
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Based on the above information, it is conclusive that the stadium would not be a physical obstruction of
the airspace used for VFR aircraft operating in the traffic pattern. There is sufficient lateral and vertical
separation of the proposed stadium from an aircraft’s path within the airspace used for VFR operations
at CLE.

It is FA&A’s opinion that the FAA’s review to determine whether a structure would be a visual
distraction during a critical phase of flight is subjective and must be determined on a cases-by-case
basis. However, a reduction of the stadium’s height by 58 feet to remain below the VFR horizontal
surface would not lessen the potential level of distraction by a consequential amount.

VFR Flyways
There are no VFR Flyways in the vicinity of the Subject Project.

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Instrument Departure Procedures

Figure 3: TERPS® image: Departure Initial Climb Areas (ICA) for all runways at CLE

The airspace used for instrument departure procedures is protected from obstructions through the use
of three different Obstacle Clearance Surfaces (OCS):

 Initial Climb Area (ICA)

 Diverse A
 Diverse B

The analysis of the instrument departure procedures at CLE found that the proposed stadium would be
located outside of the ICA for all runways. The maximum allowable height is therefore dictated by the
Diverse A and Diverse B departure surfaces, the most restrictive of which is the Diverse A OCS for
Runway 10 departures. The maximum allowable height based on this surface ranges from 1125 to 1157
feet AMSL. The project would have no adverse effect on instrument departures from CLE.

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Instrument Approach Procedures

Circling Approach Areas for each IAP

Figure 4: TERPS® image: Circling Approach Areas at CLE.

The proposed stadium is located with the circling approach areas for all categories of aircraft. The
maximum structure height at the structure’s location is based on a 300-foot Required Obstacle
Clearance (ROC) below the lowest Circling Minimum Descent Altitude (CMDA) available for any IAP.

The CMDA listed on every current approach plate is 1420 feet AMSL. Therefore, the maximum allowable
height at the project’s location is 1120 feet AMSL. The proposed stadium will have no impact on the
circling approach areas at CLE.

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Runway 06L

Figure 5: TERPS® image: Instrument Approach Procedures for Runway 6L at CLE.

The proposed stadium is located within the lateral bounds of the Obstacle Clearance Surfaces (OCS) of
several Instrument Approach Procedures for Runway 6L at CLE. The table below includes the maximum
heights based on the OCS:

Maximum Allowable
IAP Comments
Height Range (AMSL)

ILS 1344 Only northern corner within OCS

ILS Cat-II - Outside of OCS
ILS Cat-III - Outside of OCS
LOC - Outside of OCS
LPV 1344 Only northern corner within OCS
LNAV 1309 - 1354
VNAV 1270 - 1294
RNP 0.17 1259 - 1283
RNP 0.30 1284 - 1308

The project will have no effect on the Runway 6L Instrument Approach Procedures at CLE.

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Runway 06R

Figure 6: TERPS® image: Instrument Approach Procedures for Runway 6R at CLE.

The proposed stadium is located within the lateral bounds of the Obstacle Clearance Surfaces (OCS) of
several Instrument Approach Procedures for Runway 6R at CLE. The table below includes the maximum
heights based on the OCS:

Maximum Allowable
IAP Comments
Height Range (AMSL)

ILS 1198 Only northern corner within OCS

ILS Cat-II - Outside of OCS
LOC 1252 - 1282
LPV 1198 Only northern corner within OCS
LNAV 1254 - 1278
VNAV 1367 - 1391
RNP 0.15 1207 - 1231
RNP 0.30 1288 - 1313

The project will have no effect on the Runway 6R Instrument Approach Procedures at CLE.

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Runway 10

Figure 7: TERPS® image: Instrument Approach Procedures for Runway 10 at CLE.

The proposed stadium is located within the lateral bounds of the Obstacle Clearance Surfaces (OCS) of
the two Instrument Approach Procedures for Runway 10 at CLE. The table below includes the maximum
heights based on the OCS:

Maximum Allowable
IAP Comments
Height Range (AMSL)

LP 1237 - 1284
LNAV 1183 - 1216

The project will have no effect on the Runway 10 Instrument Approach Procedures at CLE.

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Runway 24L

Figure 8: TERPS® image: Instrument Approach Procedures for Runway 24L at CLE

The proposed stadium is located within the lateral bounds of the Obstacle Clearance Surfaces (OCS) of
several Instrument Approach Procedures for Runway 24L at CLE. The table below includes the maximum
heights based on the OCS:

Maximum Allowable
IAP Comments
Height Range (AMSL)

ILS - Outside of OCS

ILS Cat-II - Outside of OCS
LOC - Outside of OCS
LPV - Outside of OCS
LNAV 1043 - 1201
VNAV 1019 - 1081
RNP 0.17 - Outside of OCS
RNP 0.30 1029 - 1053

The project will have no effect on the Runway 24L Instrument Approach Procedures at CLE.

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Runway 24R

Figure 9: TERPS® image: Instrument Approach Procedures for Runway 24R at CLE

The proposed stadium is located within the lateral bounds of the Obstacle Clearance Surfaces (OCS) of
two Instrument Approach Procedures for Runway 24R at CLE. The table below includes the maximum
heights based on the OCS:

Maximum Allowable
IAP Comments
Height Range (AMSL)

ILS - Outside of OCS

ILS Cat-I - Outside of OCS
ILS Cat-II - Outside of OCS
ILS Cat-III - Outside of OCS
LOC - Outside of OCS
LPV - Outside of OCS
LNAV 1213 - 1224
VNAV 1091 - 1182
RNP 0.17 - Outside of OCS
RNP 0.30 - Outside of OCS

The project will have no effect on the Runway 24R Instrument Approach Procedures at CLE.

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Runway 28

Figure 10: TERPS® image: Instrument Approach Procedures for Runway 28 at CLE.

The proposed stadium is located within the lateral bounds of the Obstacle Clearance Surfaces (OCS) of
two Instrument Approach Procedures for Runway 28 at CLE. The table below includes the maximum
heights based on the OCS:

Maximum Allowable
IAP Comments
Height Range (AMSL)

ILS - Outside of OCS

LOC - Outside of OCS
LPV - Outside of OCS
LNAV 1010
VNAV 1007 - 1017 Stadium height is equal to 1007’ OCS height

The project will have no effect on the Runway 28 Instrument Approach Procedures at CLE.

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The following figures depict the OCS of the LPV and the VNAV Procedures. The proposed structure is
located outside of the OCS for the LPV procedure, shown in Figure 11 to address concerns that the
project would affect approach minimums for the LPV Procedure. The VNAV procedure dictates the
maximum allowable height to avoid impacting a protected procedure surface. The maximum height of
the VNAV OCS is 1007 feet AMSL, which is the height of the proposed structure. All appurtenances, such
as lightning rods, antennas, obstruction lighting, etc. must remain below this height to be in compliance
with the FAA determination.

Figure 11: TERPS® image: Runway 28 ILS/LPV Approach Procedure at CLE.

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Figure 12: TERPS® image: Runway 28 VNAV Approach Procedure at CLE.

Low Altitude Airways

There are no low altitude airways above the project’s location.

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Radio Communication Link (RCL) Propagation Path

Figure 13: TERPS® image: RCLR Path near CLE

The proposed stadium is not located within the RCL propagation path and therefore will not have an
adverse impact on FAA microwave communications.

NAVAID Impacts
The analysis found the project would have no impact on existing navigation aids. The proposed stadium
would not have an adverse effect on any ILS glideslope, localizer, VOR, DME, TACAN, NBD, VGSI, or
communications facilities.

Proposed Runways
Cleveland-Hopkins International Airport (CLE) does not have any proposed runway plans on file with the
FAA at this time.

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Private Landing Facilities

Figure 14: TERPS® image: Private Landing Facilities in the vicinity of the proposed stadium.

There are five private landing facilities within 5 NM of the proposed stadium:

Distance from
Facility
Facility Name Facility Type Proposed
Identifier
Stadium (NM)
37OH Southwest General Hospital Heliport 2.27
OH27 Cleveland Clinic Fairview Hospital Heliport 2.51
OI50 1st District Police Station Heliport 3.19
OI43 Back Achers Heliport 3.71
62OI University Hospitals Parma Medical Center Heliport 4.55

None of these facilities have Special Instrument Approach Procedures available. The project is not
expected to have an adverse effect on aeronautical operations at any nearby private landing facility.

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Conclusion
FAA Order 7400.2R states the following:

6−3−3. DETERMINING ADVERSE EFFECT

If a structure first exceeds the obstruction standards of 14 CFR part 77, and/or is found to have physical
or electromagnetic radiation effect on the operation of air navigation and/or radar/surveillance,
communications and weather facilities, then the proposed or existing structure, if not amended, altered,
or removed, has an adverse effect if it would:

a. Require a change to an existing or planned IFR minimum flight altitude, a published or special
instrument procedure, or an IFR departure procedure.
b. Require a VFR operation to change its regular flight course or altitude. This does not apply to
VFR military training route (VR) operations, operations conducted under 14 CFR part 137, or
operations conducted under an FAA–issued waiver or exemption.
c. Restrict the clear view of runways, helipads, taxiways, or traffic patterns from the airport
traffic control tower cab.
d. Derogate airport capacity/efficiency.
e. Affect future VFR and/or IFR operations as indicated by plans on file.
f. Affect the usable length of an existing or planned runway.

Based on the criteria outlined above, our analysis has determined the proposed stadium would have no
adverse effect on the safety and efficient use of the aeronautical environment. The project:

- would have no effect on VFR operations

- would not require any aircraft to change its flight course or altitude within the VFR Traffic
Pattern
- would have no effect on IFR operations
- would not require any modification to instrument approach or departure procedures or their
associated minimum altitudes or weather conditions
- would not restrict aircraft types or capacity at CLE
- would not create a hazardous situation during a critical phase of flight or emergencies
- would not reduce the maneuvering space available during takeoff or landing

Therefore, FA&A corroborates the findings of the FAA’s aeronautical study and the subsequently issued
Determination of No Hazard.

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