final report aviation impact statement - murra … · acft aircraft ad aerodrome ... ais aviation...

FINAL REPORT

AVIATION IMPACT STATEMENT QUALITATIVE RISK ASSESSMENT

AND OBSTACLE LIGHTING REVIEW

MURRA WARRA WIND FARM 220M TURBINES

Copy No.: v5.0

Report to:

RES AUSTRALIA PTY LTD

16 June 2016

The Ambidji Group Pty Ltd

A.C.N. 053 868 778

Melbourne, Australia

The information contained in this document is confidential and proprietary to The Ambidji Group Pty. Ltd. Other than for evaluation and governmental disclosure purposes, no part of this document may be reproduced, transmitted, stored in a retrieval system, or translated into any language in any form by any means without the written permission of The Ambidji Group.

RES AUSTRALIA PTY LTD MURRA WARRA WIND FARM – 220M

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16 June 2016 Commercial-In-Confidence Page i

DOCUMENT RELEASE APPROVAL

Approved for Final Release:

Name: Ian Jennings Title: Principal Consultant Date: 16 June 2016 Distribution: Kevin Garthwaite, Development Project Manager, RES Australia DOCUMENT CONTROL

REV NO

DESCRIPTION DATE Prepared QA

V0.1 Draft Report 220m turbines March 2016 IJ

V0.2 Revised Report Navaid Changes 27 May 2016 IJ BS

V1.0 Final Report 220m 27 May 2016 IJ BS

V2.0 Revised Final Report 220m 27 May 2016 IJ BS

V3.0 Revised OLR 30 May 2016 IJ BS

V4.0 Editorial 6 June 2016 IJ BS

V5.0 Editorial 16 June 2016 IJ BS

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TABLE OF CONTENTS

1. Introduction ...................................................................................................................... 5 1.1 Location .................................................................................................................... 5 1.2 Aerodromes and Airstrips .......................................................................................... 7 1.3 Aerodromes in the Area ............................................................................................. 8 1.4 Air Routes in the Area ............................................................................................... 9

Relevant Air Routes........................................................................................................ 10 1.5 Airspace .................................................................................................................. 10

2. Scope ............................................................................................................................. 10 2.1 Aviation Impact Statement ....................................................................................... 10 2.2 Qualitative Risk Assessment ................................................................................... 11 2.3 Obstacle Lighting Review ........................................................................................ 12

3. Methodology ................................................................................................................... 12 3.1 Aviation Impact Statement ....................................................................................... 12 3.2 Qualitative Risk Assessment ................................................................................... 13 3.3 Obstacle Lighting Review ........................................................................................ 14

4. Aviation Impact Statement .............................................................................................. 14 4.1 Location .................................................................................................................. 14 4.2 Obstacles ................................................................................................................ 14 4.3 Drawings ................................................................................................................. 14 4.4 Aerodromes with 30nm ............................................................................................ 15 4.5 Obstacle Limitation Surfaces ................................................................................... 16

Warracknabeal ............................................................................................................... 16 Horsham ......................................................................................................................... 16

4.6 PANS – OPS Surfaces ............................................................................................ 16 4.6.1 Warracknabeal ................................................................................................. 16 4.6.2 Horsham .......................................................................................................... 19

4.7 Air Routes and Lowest Safe Altitudes ...................................................................... 19 4.8 Airspace .................................................................................................................. 21 4.9 Communications, Navigation and Surveillance Facilities ......................................... 21

Communications ............................................................................................................. 21 Navigation Aids .............................................................................................................. 21 Surveillance (Radar) ....................................................................................................... 22

4.10 AIS Conclusions ...................................................................................................... 22 4.11 AsA Response to the AIS ........................................................................................ 23 4.12 Department of Defence Response to the AIS .......................................................... 23

5. Qualitative Risk Assessment .......................................................................................... 23 5.1 Certified or Registered aerodromes ......................................................................... 24

5.1.1 Aerodromes within 30nm (56km) ...................................................................... 24 5.1.2 Horsham Aerodrome (YHSM)........................................................................... 25 5.1.3 Warracknabeal Aerodrome (YWKB) ................................................................. 25

5.2 Airspace .................................................................................................................. 27 5.3 Relevant Air Routes ................................................................................................ 28 5.4 Night Flying ............................................................................................................. 28 5.5 General Aviation Flying Training .............................................................................. 28

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5.6 Gliding ..................................................................................................................... 29 5.7 Recreational and Sport Aviation .............................................................................. 29 5.8 Approved Low Flying Activities ................................................................................ 30 5.9 Aerial Agricultural Aviation Activities ........................................................................ 30 5.10 Known Highly Trafficked Areas ................................................................................ 31 5.11 Emergency Services Flying ..................................................................................... 31

5.11.1 Police Air Wing ................................................................................................. 31 5.11.2 Victorian Air Ambulance ................................................................................... 31 5.11.3 State Aircraft Unit ............................................................................................. 32

5.12 Firefighting .............................................................................................................. 32 5.13 Topography and Marginal Weather Considerations ................................................. 34 5.14 NASF Guidelines ..................................................................................................... 35

5.14.1 Notification to Authorities .................................................................................. 35 5.14.2 Risk Assessment .............................................................................................. 36 5.14.3 Lighting of Wind Turbines in the Vicinity of an Aerodrome ................................ 37

5.15 QRA Findings .......................................................................................................... 38 6. Obstacle Lighting Review ............................................................................................... 39

6.1 Summary of International Standards for Obstacle Lighting of Wind Farms .............. 39 6.1.1 International Civil Aviation Organisation ........................................................... 39 6.1.2 Other International Aviation Regulatory Authorities .......................................... 40

6.2 Australian regulatory framework for Obstacle Lighting of Wind Farms ..................... 41 6.2.1 Civil Aviation Safety Regulations ...................................................................... 41 6.2.2 National Airports Safeguarding Framework ...................................................... 41

6.3 Obstacle Lighting Summary..................................................................................... 43 7. Wind Monitoring Towers ................................................................................................. 43

7.1 NASAG Guideline – Marking of Meteorological Monitoring Masts ........................... 44 7.2 Federal Aviation Administration – Marking of MET towers ....................................... 44 7.3 Recommendation .................................................................................................... 45

8. Conclusions .................................................................................................................... 45 8.1 AIS .......................................................................................................................... 45

8.1.1 AsA Response to AIS ....................................................................................... 46 8.1.2 Defence Response to AIS ................................................................................ 46

8.2 Risk Assessment ..................................................................................................... 46 8.3 Obstacle Lighting ..................................................................................................... 46 8.4 Reporting of Tall Structures ..................................................................................... 47 8.5 Rationale for Partial Obstacle Lighting ..................................................................... 47

9. Duty of Care ................................................................................................................... 48

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Appendix A: Airservices Australia Aviation Assessments for Wind Farm Developments

Appendix B Murra Warra Wind Farm Site Identification, Coordinates and Elevations

Appendix C Airservices Australia Response to the AIS

Appendix D Department of Defence Response to the AIS

Appendix E Australian Fire and Emergency Services Authorities Council Wind Farms and Bushfire Operations

Appendix F SA Country Fire Service – Understanding Aerial Firefighting

Appendix G World Aeronautical Chart 3469 Hamilton

Appendix H CASA Letter February 2013

Appendix I Aeronautical Study Glossary

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ABBREVIATIONS

Abbreviations used in this report, and the meanings assigned to them for the purposes of this report are detailed in the following table:

Abbreviation Meaning AC Advisory Circular (document support CASR 1998) ACFT Aircraft AD Aerodrome AHD Australian Height Datum AIP Aeronautical Information Publication Airports Act Airports Act 1996, as amended AIA Aeronautical Impact Assessment AIS Aviation Impact Statement as required by AsA ALA Aeroplane Landing Area Alt Altitude AMSL Above Minimum Sea Level ARP Aerodrome Reference Point AsA Airservices Australia ATC Air Traffic Control(ler) CAO Civil Aviation Order CAR Civil Aviation Regulation 1988 CASA Civil Aviation Safety Authority CASR Civil Aviation Safety Regulation 1998 Cat Category DAP Departure and Approach Procedures (charts published by AsA) DME Distance Measuring Equipment DIRD Department of Infrastructure and Regional Development.

(Formerly Department of Infrastructure and Transport) DoIT Department of Infrastructure and Transport. Also called “Infrastructure”.

(Formerly Department of Infrastructure, Transport, Regional Development and Local Government (DITRDLG) and previously the Department of Transport and Regional Services (DoTARS))

DITRDLG See DoIT above DOTARS See DITRDLG above ERSA Enroute Supplement Australia FAF Final Approach Fix FAP Final Approach Point ft feet GA General Aviation GNSS Global Navigation Satellite System ICAO International Civil Aviation Organisation IFR Instrument Flight Rules km kilometres kt Knot (one nautical mile per hour)

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Abbreviation Meaning LAT Latitude LONG Longitude LSALT Lowest Safe Altitude m metres MAPt Missed Approach Point MDA Minimum Descent Altitude MGA94 Map Grid Australia 1994 MOC Minimum Obstacle Clearance MOS Manual of Standards, published by CASA MSA Minimum Sector Altitude MWWF Murra Warra Wind Farm SSR Monopulse Secondary Surveillance Radar NASAG National Airports Safeguarding Advisory Group NASF National Airports Safeguarding Framework NDB Non Directional Beacon NM or nm Nautical Mile (= 1.852 km) NOTAM NOtice To AirMen OLR Obstacle Lighting Review OLS Obstacle Limitation Surface PANS-OPS Procedures for Air Navigation Services – Aircraft Operations,

ICAO Doc 8168 PSR Primary Surveillance Radar QRA Qualitative Risk Assessment Rnnn Restricted Airspace – promulgated in AIP as R with 3 numbers RNAV aRea NAVigation RNP Required Navigation Performance RPT Regular Public Transport RWY Runway SFC Surface SOC Start Of Climb SSR Secondary Surveillance Radar VFR Visual Flight Rules VMC Visual Meteorological Conditions Defined in AIP ENR 1.2

VOR Very high frequency Omni directional Range

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EXECUTIVE SUMMARY

RES Australia Pty Ltd has engaged The Ambidji Group (Ambidji) to prepare an Aeronautical Impact Assessment (AIA), Aviation Impact Statement (AIS), Qualitative Risk Assessment (QRA) and an Obstacle Lighting Review (OLR) for the proposed wind farm at Murra Warra in the Wimmera Region of Victoria.

The proposed wind farm comprises 116 turbines with a tip height not exceeding 220m (722ft) Above Ground Level (AGL), and up to 6 meteorological masts. The highest turbine (T101) will have a tip height of 354.44m (1163ft) AHD. The final turbine and meteorological mast locations will be within the infrastructure envelope centred on the locations used in this report.

AIS Summary

The AIS incorporates the AIA for the Murra Warra Wind Farm (MWWF) and finds that it will have no impact on Airservices Australia (AsA) communications, navigation or surveillance (CNS) facilities, not impact on the obstacle limitation surfaces (OLS) for any registered or certified aerodrome.

However, the MWWF will impact on the 10nm Minimum Sector Altitude (MSA) for Warracknabeal Aerodrome (YWKB), and on the published global navigation satellite system aircraft instrument approach procedure for runway 08 at this aerodrome (YWKB RWY08 RNAV-Z). To avoid these impacts, it is recommended that AsA be requested to raise the 10nm MSA at YWKB to 2,200 feet. AsA has indicated that it is prepared to do this, subject to agreement of the aerodrome operator and CASA.

Similarly the Airport Group has agreed to a minor redesign of the YWKB RWY08 RNAV-Z procedure to increase the holding altitude to 2,200 feet.

The Department of Defence advises they have no objections to the MWWF at a maximum tip height of 354.44m AHD.

The QRA investigated the aviation activity that occurs in the area of the MWWF and at Horsham (YHSM) and Warracknabeal (YWKB) aerodromes. The risk to this aviation activity posed by the MWWF was assessed through a series of stakeholder1 interviews.

The QRA findings are summarised in the table below.

1 The list of Stakeholders is held by Ambidji and is available on request.

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Risk Element Assessed Level of

Comment

Airport Operations LOW Warracknabeal LOW Mitigated by Obstacle Lighting Horsham LOW Aircraft Landing Area Operations LOW Pilot responsibility. None identified in area Known Highly Trafficked Routes LOW None identified in the area Published Air Routes LOW Nil impact Restricted Airspace LOW Nil in the area Promulgated Flying Training Areas LOW Nil in the area Night Flying LOW Emergency Services Flying LOW Commercial Flying LOW Recreational and Sport Aviation LOW By day only Recreational Pilot Training (RA-AUS) LOW By day only GA Flying LOW GA Pilot Training LOW Weather and Topographical Issues LOW

Risk Summary

The Murra Warra Wind Farm is assessed as not being a hazard to aircraft safety by day and by night when recommended mitigation is provided.

It is considered that YWKB requires Obstacle Lighting on some of the MWWF turbines to mitigate the risk to night operations of aircraft at that aerodrome.

The lighting of turbines T250, T257, T256, T255, T258 and T254 will mitigate the risk to night operations at YWKB by indicating the line of obstacles closest to the aerodrome. To maintain visual amenity it is recommended that these obstacle lights operate on a Pilot Activated Lighting (PAL) system operating on the same frequency as the YWKB aerodrome lighting.

It is considered that once the mitigations are in place, the risk to aircraft safety is acceptable and the MWWF will not be a hazard to aircraft safety and therefore “not of operational significance” to aircraft operations.

CASA has no specific authority to require action for the obstacle marking and lighting of wind turbines located away from certified or registered aerodromes and cannot impose a requirement for their provision2.

2 CASA Letter; Current CASA approach to the impact of tall structures, including wind turbines and wind monitoring masts on aviation, February 2013. See Appendix H

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1. INTRODUCTION

RES Australia Pty Ltd has engaged The Ambidji Group (Ambidji) to prepare an Aeronautical Impact Assessment (AIA), Aviation Impact Statement (AIS), Qualitative Risk Assessment (QRA) and an Obstacle Lighting Review (OLR) for the proposed wind farm at Murra Warra in the Wimmera Region of Victoria.

The areas of investigation for the AIA and the AIS are the same with the addition of Communications, Navigation and Surveillance (CNS) in the AIS. The AIS was submitted to Airservices Australia (AsA) as a separate report. The AIS is now incorporated into this document and jointly reported with the AIA under the AIS heading. The AsA response to the AIS for the MWWF is shown at Appendix C and the Department of Defence response is shown at Appendix D.

The QRA analyses the risks to aviation posed by the proposed wind farm development through facilitated interviews with stakeholders and outside experts as to their probability of occurrence and impact expressed using non-numerical terminology. The basis for the QRA is ASNZS ISO 31000-2009 Risk Management – Principles and Guidelines.

The OLR follows from the QRA and establishes the need or otherwise for turbines in the wind farm to be lit with medium intensity aviation obstruction lighting.

1.1 Location

The MWWF development is located approximately 28km north east of Horsham in the Wimmera Region of Victoria. The general location of the MWWF is shown in Figure 1.1.1 and the general turbine layout is shown at Figure 1.1.2.

The proposed wind farm comprises 116 turbines with a tip height not exceeding 220m (722ft) AGL and up to 6 meteorological masts. The highest turbine (T101) will have a tip height of 354.4m (1163ft) AHD. The final turbine and meteorological mast locations will be within the infrastructure envelope centred on the locations used in this report.

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Figure 1.1.1 – Murra Warra Wind Farm Location

Figure 1.1.2 – Murra Warra Wind Farm Turbine Layout3

3 Supplied by RES

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1.2 Aerodromes and Airstrips

Aerodromes fall into four categories:

Military or Joint (combined military and civilian); Certified; Registered; and Uncertified or Aeroplane Landing Areas

A Military aerodrome is operated by the Department of Defence and is suitable for the operation of military aircraft. A Joint User aerodrome is a Military aerodrome used by both military and civilian aircraft, for example Darwin International and Townsville International Airports.

A Certified Aerodrome, certified under Civil Aviation Safety Regulation (CASR) 139.040, is available for Regular Public Transport and Charter operations and has a runway suitable for use by an aircraft having a maximum carrying capacity of more than 3,400kg or a passenger seating capacity of more than 30 seats, for example Melbourne International Airport, Mildura Airport and Portland Airport.

A Registered Aerodrome, registered under CASR 139.260, is one to which CASR 139.040 does not apply and the operator has applied to the Civil Aviation Safety Authority (CASA) to have it registered, for example Horsham, Warracknabeal, Stawell and Ararat Airports.

An Uncertified Aerodrome is any other aerodrome or airstrip and is referred to as an Aeroplane Landing Area (ALA). These range in capability and size from having a sealed runway with lighting capable of accommodating corporate jet aircraft to a grass paddock that is smooth enough to land a single engine light aircraft or a purpose built aerial agricultural aircraft.

Military, Certified and Registered aerodromes are listed in the Aeronautical Information Publication4 (AIP) and are subject to a NOTAM5 service that provides the aviation industry with current information on the status of the aerodrome facilities. This information is held in the public domain, is available through aeronautical publications and charts and is kept current by mandatory reporting requirements.

Uncertified aerodromes (ALA) are not required to be listed in the AIP so information about them is not held in the public domain, is not available through aeronautical publications and charts and is not required to be reported. Where ALA information is published in the AIP it is clearly annotated that it is not kept current. Consequently ALA can come into use and fall out of use without any formal notification to CASA or any other authority. Airstrips that appear on survey maps often no longer exist; others exist but do not feature on maps. Similarly a grass paddock used as an ALA is not usually discernable on satellite mapping services such as Google Earth.

4 AIP; a mandatory worldwide distribution system for the promulgation of aviation rules, procedures and information 5 NOTAM (Notice to Airmen); a mandatory reporting service to keep aerodrome and airways information current and available to the aviation industry world wide

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Military, Joint, Certified and Registered aerodromes usually have Obstacle Limitation Surfaces (OLS) and Procedures for Air Navigation – Operations (PANS-OPS) surfaces prescribed to protect the airspace associated with published instrument approach and landing procedures. An uncertified aerodrome or ALA cannot have a published instrument approach and landing procedure so cannot have associated prescribed airspace protected by OLS or PANS-OPS. All operations into ALA therefore, must be conducted in accordance with the Visual Flight Rules (VFR) and in Visual Meteorological Conditions (VMC).

1.3 Aerodromes in the Area

There are two registered aerodromes within 56km (30nm) of the proposed wind farm. These are Warracknabeal (YWKB) and Horsham (YHSM) and their location in relation to the wind farm is shown in Figure 1.3.1 below.

Figure 1.3.1 – Murra Warra Wind Farm Location relative to

Horsham (YHSM) and Warracknabeal (YWKB) aerodromes6

6 Compiled from information supplied by RES

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1.4 Air Routes in the Area

There are published air routes above and near the proposed Murra Warra Wind Farm. These air routes are used by aircraft flying in accordance with Instrument Flight Rules (IFR), whereby they are able to fly in cloud and at night. Each route has a published Lowest Safe Altitude (LSALT) which is clear of any obstacles.

The Air Routes are shown in Figure 1.4.1 below.

Figure 1.4.1 – Air Route locations in vicinity of Murra Warra Wind Farm7

7 AIP ERC L2 26 May 2016

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Relevant Air Routes

The Air Routes and Lowest Safe Altitudes relevant to the MWWF are tabulated below in Table 1.4.1

Air Route Segment Lowest Safe Altitude LSALT

GRID 3900 W476 TURBI - TIEGA 1800 W414 UBGUT – TURBI – SWH 2600/2000 W475 UGPUR – TURBI – PUBAP 2800/2300 W291 UBGUT – PUBAT 2300 W584 UBGUT – MI 2600 W306 TURBI – BURRA 4700

Table 1.4.1 – Air Routes in vicinity and LSALTs

1.5 Airspace

The MWWF is situated in non-controlled Class G airspace below controlled Class E airspace with a lower limit of FL180.

There is no Military, Prohibited, Restricted or Danger Area airspace in the vicinity.

There are no promulgated Flying Training Areas in the vicinity.

The MWWF will not impact on the use of Class G airspace by commercial, recreational, general and gliding aviation activity.

2. SCOPE

To meet RES Australia’s requirements, the study required Ambidji to examine the proposed MWWF development and undertake the following tasks.

2.1 Aviation Impact Statement

In August 2014, AsA re-released a letter detailing requirements for an Aviation Impact Statement for wind farm developments. The AsA letter requires that all developers of proposed wind farms prepare an Aviation Impact Statement, and submit this to AsA for evaluation and consideration. A copy of this letter is shown at Appendix A.

The AIS required the following tasks to be undertaken: -

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Provide the coordinates and elevations of the Obstacles and associated topographical drawings;

Specify all registered and certified aerodromes within 30nm (55.6km):

• Nominate all instrument approach and landing procedures; • Confirm that the obstacles do not penetrate the Annex 14 OLS; • Confirm that the obstacles do not penetrate the PANS-OPS;

Specify any published air routes over or near the obstacles

Specify the airspace classification of the airspace surrounding the development

Investigate any impact on aviation Communications, Navigation and Surveillance (CNS) facilities

Details of Aerodromes, OLS, PANS-OPS procedures, Lowest Safe Altitudes, Navigation and Airspace Surveillance facilities were obtained from the Australian Aeronautical Information Publications (AIP), AsA sources and CASA publications.

The AIS was revised to accommodate the impact of the AsA Navigation Aid Rationalisation program effective 26 May 2016 whereby the NDB’s at YHSM, YWKB and YNHL were removed from service. This program coincided with the change in parameters for calculating LSALT from conventional to RNP 2, whereby the tolerances are smaller. This has consequences when reviewing any impact the MWWF may have on published air routes. The removal of navigation aids cancels some instrument Departure and Approach Procedures, requiring reconsideration of the impact the MWWF may have on them.

2.2 Qualitative Risk Assessment

The QRA required the following tasks to be undertaken: -

The identification and assessment of potential aviation risk elements through:

• Reference to CASA publications; • Reference to the AIP; • Reference to the National Airports Safeguarding Framework (NASF)

guidelines; • Consultations with key relevant stakeholders;

Assessment of the perceived impacts of the turbines on the operation of aerodromes and airstrips in the immediate vicinity of the wind farm;

Assessment of the perceived impacts of the turbines on aviation activity including:

• General Aviation training; • Recreational/Commercial flying activity; • Air Ambulance Operations; • Police Aviation Operations;

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• Aerial Fire Fighting Operations; • Aerial Agricultural Operations; • Known highly trafficked VFR routes; • Night flying for light aircraft;

Assessment of any implications for the above from topographical, weather and visibility issues;

Assessment of other issues as identified through consultations and the assessment process;

Conclusions on the degree of aviation risk posed by the above described issues with commensurate recommendations on any mitigating actions.

An assessment of the need, against the outcomes of the Qualitative Risk Assessment, for obstacle lighting of the wind farm.

2.3 Obstacle Lighting Review

The OLR reviews the outcome of the QRA to determine the need or otherwise for aviation obstruction lighting of turbines in the wind farm.

3. METHODOLOGY

The following methodology was used to complete the tasks outlined in the scope.

3.1 Aviation Impact Statement

To meet Airservices Australia requirements for an Aviation Impact Statement the following methodology was used: -

The obstacle (turbines and meteorological masts) coordinates and elevations were listed to the requisite accuracy and associated drawings and charts were obtained;

The AIP was reviewed to determine;

• All registered/certified aerodromes located within 30nm (55.6km) of the wind farm

• Any associated Instrument Departure and Approach Procedures (DAP);

• The extent of the OLS and PANS-OPS surfaces for the identified DAP;

• Published air routes located over or near the wind farm; • The classification of the airspace surrounding the wind farm;

Ascertain the locations of CNS facilities that may be impacted and analyse the impact on;

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• Communications facilities; • Navigation facilities; • Surveillance facilities (in accordance with EUROCONTROL

Guidelines); and

Compile a report for review by Airservices Australia.

3.2 Qualitative Risk Assessment

A Qualitative Risk Assessment is the analysis for risks, through facilitated interviews or meetings with stakeholders and outside experts, as to their probability of occurrence and impact expressed using non-numerical terminology; for example low, medium and high. The basis for the QRA is ASNZS ISO 31000-2009 Risk Management – Principles and Guidelines.

The methodology for the Qualitative Risk Assessment was as follows:

The Australian AIP and CASA documents were reviewed to identify relevant physical and operational aviation issues that may impact on the requirement for lighting of the wind farm;

Current topographical maps were studied to assess the local terrain and identify any local airstrips and any other relevant features;

Key stakeholders, including local operators, recreational aviation groups and State Government Police Air Wing, Air Ambulance and Fire Services, were identified, contacted and surveyed to ascertain the extent of local aviation activity in the vicinity of the proposed wind farm. This included any informal low flying areas and highly trafficked unpublished air routes that may exist within the vicinity of the proposed wind farm;

Based on the above, the nature of any impacts as a consequence of the operation of the wind farm was considered and discussed in regard to;

• General Aviation training; • Recreational and sport aviation activities; • Approved low flying activities (including aerial agricultural applications) • Any known highly trafficked VFR routes; and • Emergency Services (air ambulance, police and fire service);

In addition, further consideration was given to the consequences (for the above elements) of the potential influence of topography and poor weather;

Consideration of the NASF, Guideline D Managing the Risk to Aviation Safety of Wind Turbine Installations (Wind Farms)/Wind Monitoring Towers in relation to the QRA findings.

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3.3 Obstacle Lighting Review

The Obstacle Lighting Review investigates the current International and Australian standards and regulatory requirements for obstacle lighting of wind farms. From this review an assessment of the need or otherwise for aviation obstruction lighting is made.

The methodology for the Obstacle Lighting Review was as follows: -

Summarise current International standards and regulatory requirements;

Review the Australian regulatory requirements and standards;

Review the NASF Guidelines for wind farms; and

From the QRA, assess the need for aviation obstruction lighting as a risk mitigator.

4. AVIATION IMPACT STATEMENT

The AIS includes the AIA and is documented as the AIS.

4.1 Location

The location of the proposed MWWF is shown in Figures 1.1.1 and 1.1.2 above.

4.2 Obstacles

A list of the proposed wind turbine locations is shown in Appendix B. The turbines have been considered as an envelope of 100 m radius and height of 220 m AGL, centred on the turbine site coordinates.

Envelope central coordinates are in WGS 84, accurate to 0.1 second of arc and elevations Above Mean Sea Level (AMSL) are accurate to 0.5 metres. The final turbine and meteorological mast locations will be within the infrastructure envelope centred on these locations. The final elevations will be accurate to 0.3m.

The highest obstacle, turbine T101 at 354.44m (1163ft) AHD is shown in yellow shading (Appendix B.)

4.3 Drawings

A drawing of the proposed MWWF is shown at Figure 1.1.2 and a copy showing the

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final turbine locations in electronic format compatible with Microstation version 81 has been provided to AsA.

A Google Earth (GE) image showing the identification and location of each turbine site and the identification of the highest obstacle (turbine number T101 at 1163ft AHD) is shown in Figure 4.3.1. The micro-siting of T257 is no longer critical in relation to LSALT calculations.

Figure 4.3.1 GE image of the Murra Warra Wind Farm showing Wind Turbine Locations

4.4 Aerodromes with 30nm

There are two registered aerodromes within 30nm of the MWWF;

Warracknabeal (YWKB), 5.06nm (9.36km) to the North East of the wind farm boundary; and

Horsham (YHSM) 12.9nm (23.87km) to the South of the wind farm boundary.

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4.5 Obstacle Limitation Surfaces

Warracknabeal

OLS surfaces for YWKB extend to 5.5km from the runway thresholds. As the nearest runway threshold is 9.04km from the nearest MWWF boundary, the wind farm is clear of the OLS.

Horsham

OLS surfaces for YHSM extend to 5.5km from the runway thresholds. As this airfield is 23.87km from the nearest MWWF boundary, the wind farm is clear of the OLS. .

The OLS surfaces for Warracknabeal and Horsham aerodromes will not be impacted by the Murra Warra Wind Farm.

4.6 PANS – OPS Surfaces

All altitudes in PANS-OPS procedures are in feet (ft) AHD, distances are in Nautical Miles (nm) and bearings are in degrees magnetic (M). The magnetic variation in the area is 10° east. Aircraft performance category (CAT) is published in the CASA MOS Part 173.

4.6.1 Warracknabeal

Minimum Sector Altitude (MSA)

The MSA is 2200ft within 25nm of the WKB ARP (36 19 16S 142 25 10E) and is 1700ft within 10nm, as shown in Figure 4.6.1.1. As most of the MWWF is within 10nm of the WKB ARP, it is impacted by the 10nm MSA of 1700ft. See Fig 4.6.1.1.

When the Minimum Obstacle Clearance of 1000ft is applied to the highest tip AHD of 1163ft, the result is 2163ft. This height will penetrate the MSA by 463ft.

To avoid penetration of the MSA, the turbine tip heights would have to be reduced by up to 121m.

The MSA within 10 nm will need to be increased to 2200 ft, to avoid penetration by the MWWF. AsA has responded that this can be approved however “the proponent will need to consult with the aerodrome operator and CASA to secure agreement and to ensure the above change will not adversely impact on the operations of Warracknabeal aerodrome”.

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RWY 26 NDB APPROACH

The YWKB RWY 26 NDB Approach is cancelled as at 26 May 2016.

RWY 08 RNAV-Z (GNSS) APPROACH

This procedure becomes effective on 26 May 2016. As it was designed by The Airport Group and not Airservices Australia an assessment of any impact by the MWWF on this procedure and its PANS-OPS surfaces is part of this revised AIS.

A copy of the procedure is shown in Figure 4.6.1.1.

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Figure 4.6.1.1 - YWKB RWY 08 RNAV-Z (GNSS) Approach Procedure

The navigation tolerances applicable to the Initial, Intermediate and Final approach segments of the procedure have been plotted on the diagram in Figure 4.6.1.2. The navigation tolerances are those in ICAO Doc 8168 PANS-OPS Vol II Page III-1-2-4. The boundaries of the MWWF are also shown.

Figure 4.6.1.2 – RWY 08 RNAV-Z Navigation Tolerance area and the MWWF

As can be seen in Figure 4.6.1.2, the MWWF is clear of the combined navigation tolerance area from WKBWD (IF holding waypoint) to WKBWI (IF) to WKBWF (FAF).

The holding area tolerances at WKBWD are not shown, but have been calculated to extend to approximately 9.5nm from WKBWD in the direction of the MWWF. As the nearest boundary of the MWWF is 3.9nm from WKBWD, the holding area tolerance extends over the MWWF.

When the 1000ft MOC is applied to the highest turbine tip of 1163ft, the result is 2163ft, which is above the holding altitude of 2100ft.

In order to provide a safe clearance above the MWWF, the holding altitude of 2100ft will need to be increased to 2200ft. The other IF altitudes may also need to be

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increased to 2200ft for consistency, which will mean that the 3° descent from 2200ft on final approach will need to be commenced slightly earlier, however this will not result to any increase in risk to safety or the regularity of operations.

A submission for approval to raise the holding altitude at WKBWD will need to be made to CASA and The Airport Group. The developer may be charged by The Airport Group for the cost of preparing the revised procedure and its publishing in the AIP DAP.

4.6.2 Horsham

Airservices Australia has advised the following: With respect to procedures designed by Airservices in accordance with ICAO PANS-OPS and Document 9905, at the various heights provided, the wind farm turbines will not affect any instrument sector or circling altitude, nor any instrument approach or departure at Horsham aerodrome.

All procedures at Horsham were designed by Airservices Australia, and AsA has advised that the MWWF will not impact on these procedures.

4.7 Air Routes and Lowest Safe Altitudes

A number of published air routes are in the vicinity of and over the MWWF as shown in Figure 4.7.1 below.

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Figure 4.7.1 – Air Route locations in vicinity of Murra Warra Wind Farm8

8 AIP ERC L2 26 May 2016

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The GRID Lowest Safe Altitude (LSALT) and significant air route LSALT are shown in Table 4.7.1

Table 4.7.1 LSALTs in the vicinity of MWWF

The highest turbine tip is 1163ft, and when the MOC of 1000ft is applied the result is 2163ft. This is above the LSALTs on routes W476 (1800ft) and W414 WKB-SWH (2000ft).

AsA has responded with the following statement regarding Air Routes and LSALT’s:

The LSALT changes from Conventional to RNP and the wind farm no longer impacts the air route.

4.8 Airspace

The MWWF is situated in non-controlled Class G airspace below controlled Class E airspace with a lower limit of FL180.

There is no Military, Prohibited, Restricted or Danger Area airspace in the vicinity.

There are no promulgated Flying Training Areas in the vicinity.

4.9 Communications, Navigation and Surveillance Facilities

Communications

There are no AsA communications facilities located at or within 30nm of the MWWF.

Navigation Aids

The NDB’s at YWKB and YHSM are decommissioned on 26 May 2016. From this date there are no navigation aids in the vicinity of the MWWF.

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Surveillance (Radar)

The nearest AsA Radar installations are at Summertown, 366km to the North West, and Mt Macedon, 225km to the south east.

Both of these radars are too far from the MWWF for the wind turbines to have any impact on radar performance.

AsA has responded as follows:

-- CNS FACILITIES --

This proposal for the Murra Warra Wind Farm at the locations provided to a max height of 220m AGL or 354.44m AHD will not adversely impact the performance of any Airservices Precision/Non-Precision Nav Aids, Anemometers, HF/VHF/UHF Comms, A-SMGCS, Radar, PRM, ADS-B, WAM or Satellite/Links.

4.10 AIS Conclusions

The AIS for the Murra Warra Wind Farm has made the following conclusions:

The Murra Warra Wind Farm development will NOT impact upon the following:

The OLS published for any registered or certified aerodrome;

The PANS-OPS surfaces for procedures designed by AsA;

The operation of any Navigation, Communication and Surveillance (CNS) facilities.

However the Wind Farm WILL impact upon the following:

The 10 nm Minimum Sector Altitude (MSA) for Warracknabeal Aerodrome;

The RWY 08 RNAV (GNSS) approach holding altitude at WKBWD for Warracknabeal Aerodrome.

Mitigation actions to minimise or avoid the above impacts have been discussed in the relevant sections of the AIS, and are summarised as follows:

The 10nm MSA for Warracknabeal to be increased from 1700ft to 2200ft, and AsA has responded that this can be approved following discussions with CASA and the Aerodrome Operator;

The RWY 08 RNAV (GNSS) approach holding altitude at WKBWD will need to be increased from 2100 ft to 2200 ft. Requests to increase the holding altitude will need to be sent to CASA and The Airport Group as this

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procedure was not designed by Airservices Australia. The developer may have to meet the costs of revising and publication of this procedure if amendments are approved.

4.11 AsA Response to the AIS

The AsA response to the AIS is shown at Appendix C.

AsA advice is that the MWWF will: -

Not impact on any Airservices CNS facilities;

Not impact on DAP, OLS or PANS-OPS surfaces at YHSM;

Not impact on any LSALT;

Impact on the 10nm MSA for YWKB;

AsA further advises that the YWKB 10nm MSA could be raised from 1700ft to 2200ft by Permanent NOTAM.

4.12 Department of Defence Response to the AIS

The Department of Defence response to the AIS is shown at Appendix D.

Defence advises that they have no objection to the proposed development at a maximum tip height of 354.44m AHD. They remind RES Australia of their responsibility to report tall structures in accordance with AC 139-08 – Reporting of Tall Structures.

Defence also advise that “… … should LED obstruction lighting be required for these turbines, the frequency of the LED light emitted must fall within the range of wavelengths 655 to 930 nanometres. This frequency range would be visible to aircrews, operating in or through the area using night vision devices.”

5. QUALITATIVE RISK ASSESSMENT

The expression “in the vicinity of the aerodrome” is considered by CASA to mean within the boundaries of either the OLS or the PANS-OPS surfaces.

The NASF Guideline D considers 30km (16.2nm) from a certified or registered aerodrome to be “in the vicinity.”

More generally the impact on any aerodrome within 56km (30nm) of a wind farm is considered.

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5.1 Certified or Registered aerodromes

There are four registered aerodromes within 65km (35nm) of the proposed MWWF. These are: -

Aerodrome ICAO Code Distance from WF Direction from WF

Warracknabeal (Registered) YWKB 9.5km 5.1nm NNE Horsham (Registered) YHSM 23.9km 12.9nm SW Donald (Registered) YDOD 56.3km 30.4nm E Nhill (Registered) YNHL 57.3km 30.9nm WNW

Table 5.1.1 – Registered Aerodromes

There is an ALA at Rainbow which is 63.3km (34.2nm) North North West of the MWWF. There are no details shown in AIP EnRoute Supplement Australia (ERSA) for this ALA.

The four registered aerodromes are equipped with runway lighting for night operations, with Horsham, Nhill and Warracknabeal having published Instrument Departure and Approach (DAP) procedures allowing for aircraft operating to the Instrument Flight Rules (IFR) to land and take-off at night or during periods of inclement weather.

Each of these aerodromes has prescribed airspace associated with the Obstacle Limitation Surface (OLS) and Procedures for Air Navigation Services – Aircraft Operations (PANS-OPS) surfaces protecting the instrument approach paths.

5.1.1 Aerodromes within 30nm (56km)

The two registered aerodromes, Horsham and Warracknabeal, within 56km (30nm) of the MWWF are the only ones considered in detail in this QRA.

The MWWF uses turbines of 220m (722ft) in height which is well above the 110m used by CASA and the 150m used by the NASF Guideline D as trigger heights for reporting as tall structures and consideration as an obstacle and therefore a hazard to aircraft safety.

The MOS 1399 requires any object of 150m or taller to be regarded as an obstacle unless assessed otherwise by CASA.

For Warracknabeal, the MWWF is inside the 10nm MSA for the RNAV-Z instrument approaches.

9 CASR Part139 Manual Of Standards - Aerodromes

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5.1.2 Horsham Aerodrome (YHSM)

Horsham Aerodrome is 12.9nm (23.87km) to the south of the MWWF boundary. YHSM has the following Instrument Departure and Approach Procedures (DAP):

RNAV (GNSS) RWY 08; and

RNAV (GNSS) RWY 26.

The OLS for YHSM extends to 5.5km from the runway thresholds. As the aerodrome is 23.87km from the MWWF boundary, the wind farm is clear of the OLS.

The MSA for these instrument approaches is 2200ft within 10nm of the Aerodrome Reference Point (ARP) and 2400ft within 25nm of the ARP.

When the Minimum Obstacle Clearance (MOC) of 1000ft is applied to the highest turbine tip of 1163ft the result is 2163ft which is below the MSA for YHSM.

The two Instrument Departure and Approach Procedures for YHSM are NOT impacted by the Murra Warra Wind Farm.

Night Visual Flight Rules operations are also governed by published LSALT. Descent into an aerodrome for VFR at night should not normally proceed below the LSALT until the aircraft is within 3nm from the aerodrome and in VMC. The MWWF is more than 10nm from YHSM; therefore Night VFR operations will not be impacted.

The MWWF is sufficiently distant from YHSM to not be a hazard to aircraft safety and therefore “not of operational significance” to aircraft operations. Obstacle lighting is not required.

5.1.3 Warracknabeal Aerodrome (YWKB)

Warracknabeal Aerodrome is 5.06nm (9.36km) to the north east of the MWWF boundary. YWKB has the following Instrument Departure and Approach Procedures (DAP):

RNAV-Z (GNSS) RWY 08; and

RNAV-Z (GNSS) RWY 26.

The OLS for YWKB extends to 5.5km from the runway thresholds. As the aerodrome is 9.36km from the MWWF boundary, the wind farm is clear of the OLS.

The MSA for these instrument approaches is 1700ft within 10nm of the ARP and 2200ft within 25nm of the ARP.

Applying the MOC of 1000ft to the highest turbine tip of 1163ft gives a result of 2163ft which penetrates the 10nm MSA for YWKB by 463ft.

To overcome this penetration it is recommended that AsA be requested to increase the

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10nm MSA to 2200ft within the sector over the wind farm.

The RWY 26 RNAV-Z approach is not impacted by the MWWF. The RWY 08 RNAV-Z approach is impacted by the MWWF. This impact can be mitigated by a minor redesign of the procedure.

Night Visual Flight Rules operations are also governed by published LSALT. Descent into an aerodrome for VFR at night operations does not normally proceed below the LSALT/MSA until the aircraft is within 3nm from the aerodrome and in VMC. Assuming AsA amends the 10nm MSA for YWKB then night VFR operations will not be impacted.

Given the proximity of the 220m tall turbines to the Warracknabeal aerodrome they could be considered to pose a MEDIUM risk and therefore be a hazard to aircraft operations.

However, this risk is recast as LOW given the mitigators of: -

Being outside the OLS;

Not infringing the PANS-OPS surfaces, once the MSA for the segment over the MWWF is raised and the RWY 08 RNAV-Z Arrival Procedure is amended;

Not infringing LSALT;

Not infringing the runway centrelines;

Only Runway 08/26 has runway lighting;

Being marked on the appropriate aeronautical charts including DAP;

Being conspicuously marked/coloured against the general background;

Being lit by aviation obstacle lighting at night;

Being reported as tall structures in accordance with AC 139-08(1);

Being notified to local flying clubs/operators at YHSM and YWKB;

Being notified to Aerial Agricultural operators in the area and to the AAAA; and

Not being a highly trafficked aerodrome.

By day the turbines of the MWWF will be highly visible due to their white colour contrasting to the surrounding landscape, that is, they are conspicuously marked.

For night operations at YWKB the turbines closest to the aerodrome should be lit with aviation obstacle lighting to ensure their presence is conspicuous. These are turbines T250, T258, T255, T256, T257, and T254. See Figure 5.3.1. Lighting these turbines provides an arc of obstruction lights that will indicate the extent of the obstacle to aircraft departing from Runway 08 with a left turn or arriving for Runway 08 via a left downwind circuit entry. These turbines are outside the circling area and do not penetrate the OLS, and once the 10nm MSA has been raised in the sector over the

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wind farm and RWY 08 RNAV-Z procedure is modified, will not penetrate the PANS-OPS surfaces..

Consequently obstacle lighting will reduce “the risk to aircraft safety to an acceptable level.”

To maintain aviation safety and the visual amenity of the area it is recommended that these lights be activated by a Pilot Activated Lighting (PAL) system operating on the same frequency as the PAL at YWKB. This will ensure that when an aircraft intends a night operation at YWKB and activates the PAL aerodrome lighting, the obstruction lighting on the turbines will also activate.

Figure 5.3.1 Turbines nearest to YWKB

5.2 Airspace

The wind farm is situated in Class G airspace below Class E airspace with a lower limit of FL180. Operations within Class G airspace are not subject to air traffic control and aircraft operate on a “see and avoid” and “broadcast” procedure to maintain situational awareness of the relative locations of other aircraft within the area.

There is sufficient Class G airspace above the MWWF to avoid any restrictions to

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aircraft operations due to the close proximity of controlled airspace.

5.3 Relevant Air Routes

The published Air Routes and Lowest Safe Altitudes relevant to the MWWF are tabulated below in Table 5.3.1.

Table 5.3.1 – Air Routes in vicinity and LSALTs

The MWWF does not impact any air routes.

5.4 Night Flying

Aircraft flying at night under either IFR or VFR are protected by published or calculated LSALT and descent below the LSALT is restricted to within 3nm (5.4km) of the aerodrome for a visual approach to land. Where an IFR aircraft is using a published instrument approach it is protected by PANS-OPS surfaces.

5.5 General Aviation Flying Training

There is an active aero club and gliding club at Horsham. Both these groups conduct flying training at Horsham. The amount of GA traffic in the general area is considered to be ‘light’ compared to the large flying training areas such as Ballarat, Point Cook and closer to Melbourne.

All ab-initio flying training is conducted in accordance with the Visual Flight Rules (VFR) as defined in Division 3 of the Civil Aviation Regulations 1988 (CAR). VFR operations may be flown in accordance with CAR 157 Low Flying, which states, in part, that an aircraft must not be flown lower than 500ft (152m) above the highest terrain or obstacle on or within a radius of 600m for fixed wing aircraft and 300m for helicopters. This requirement does not apply if the aircraft is engaged in approved low flying activity. A pilot flying by day in accordance with the VFR must maintain a forward visibility of 5km as well as remain clear of cloud and in sight of the ground or water. Given these requirements and the high conspicuity of wind turbines the MWWF poses minimal risk to flying training.

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A comment was made by a stakeholder that “not all pilots have the latest maps and charts.” This is very poor airmanship and contrary to the rules of aviation. A mitigating factor would be “that the pilots who do not have the latest maps and charts” only fly occasionally, rarely at night, and therefore the risk they pose to the MWWF is LOW.

5.6 Gliding

The area around Horsham is used for recreational and competition gliding.

The Gliding Federation of Australia advises that wind farms are considered in a similar manner to forests; a glider cannot be landed safely in either so the pilot will stay well away from them.

The Director of the Horsham Week Gliding Competition, a major gliding competition with International competitors, advises that wind farms have little impact on modern gliding because the gliders are very high performance aircraft that can glide for a considerable distance for minimal loss of altitude. Normal competition gliding, particularly for long distance cross country events, is conducted at altitudes above 10,000ft. As noted above, gliders at low

level stay away from areas where they cannot land. It is considered that the risk of a glider colliding with a wind turbine is LOW.

5.7 Recreational and Sport Aviation

There is recreational and sport aviation flying and training conducted at Horsham aerodrome. The Chief Flying Instructor for Recreational Aviation Australia (RA-Aus) training at Horsham advises that the MWWF will have very little impact on the operations of recreational and sport aircraft as they have:

No high traffic routes;

No inclement weather routes;

No night flying; and

No landing strips in or through the wind farm area.

Recreational and Sport aircraft are limited to daytime flight in accordance with the Visual Flight Rules (VFR). This requires the aircraft to remain clear of cloud and a minimum of 500ft above the ground or highest obstacle thereon.

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5.8 Approved Low Flying Activities

There are no promulgated flying training areas depicted on the relevant aeronautical charts that will impact the Murra Warra Wind Farm.

There are no Military, Restricted, Danger or Low Flying areas depicted on the relevant aeronautical charts that will impact on the Murra Warra wind Farm.

5.9 Aerial Agricultural Aviation Activities

The Aerial Agricultural Association of Australia opposes wind farm developments unless the developer has (inter alia):

Consulted in detail with local operators; Received independent expert advice on safety and economic impacts; and Considered the impacts on the aerial application industry.10

An aerial agricultural operator made the comment that “the decision to host wind turbines is one made by the landholder who must accept that there will most probably be limitations to any aerial applications on the property11.”

Discussion with staff at the Regional office of the Victorian Department of Environment, Land, Water and Planning (DELWP) indicates that aerial agricultural applications is used for mouse baiting and locust control as well as fertilizer, insecticide and fungicide applications. The staff noted that large ground based applications equipment was used more than aerial application as it was more cost effective.

Consultation with aerial agricultural operators at Nhill, Warrnambool and Derrinallum indicates that the area from Nhill to Horsham, Beulah, Kaniva and back to Nhill is an area where aerial agricultural application of fertilizer, insecticide and fungicide is used. The MWWF is within this area.

One operator expressed interest in the letter of agreement established between an aerial agricultural applications operator and a wind farm operator in South Australia, whereby the wind farm operator will shut down and ‘park’ particular turbines to facilitate aerial agricultural applications operations close to the wind farm.

10 http://www.aerialag.com.au/ResourceCenter/Policies.aspx 11 Expert opinion obtained by the author during previous QRA work

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5.10 Known Highly Trafficked Areas

There are no known highly trafficked areas in the vicinity of the wind farm. The flying training organisations at Horsham advise that they do not have any training areas in the area of the proposed MWWF. They do use the route from Horsham to Warracknabeal for visual navigation training and as such will be aware of any enroute obstacles.

5.11 Emergency Services Flying

5.11.1 Police Air Wing

The Police Air Wing provides predominantly helicopter operations for the Victoria Police. The Police do, from time to time utilise fixed wing aircraft charter to undertake police operations. Predominantly these charter operations are conducted as IFR flights.

The helicopter operations are often conducted at low level and at night. The Chief Pilot of the Air Wing advises that wind farms are another obstacle to be considered in the flight planning stage and during the ongoing dynamic risk assessment for each operation. Provided that the wind farm details are clearly marked on the appropriate aeronautical charts they do not

pose any significant impediment to the helicopter operations. During the day wind turbines are large visible obstacles to be avoided. At night, operations generally remain clear of the wind farm area. The police helicopters are equipped with night vision enhancement equipment which may permit them to operate in close proximity to the turbines at night.

5.11.2 Victorian Air Ambulance

The Victorian Air Ambulance uses both fixed wing and helicopter aircraft. Both the fixed wing and helicopter aircraft are capable of IFR flight. The helicopter operations are sometimes conducted at low level for patient retrieval from accident sites.

Fixed Wing Operations

The Senior Base Pilot for the fixed wing air ambulance advises that their operations

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are conducted in accordance with the IFR so the wind farm will have no impact.

Helicopter Operations

The helicopter operations are often conducted at low level and at night. The Chief Pilot of Australian Helicopters advises that wind farms are another obstacle to be considered in the flight planning stage and during the ongoing dynamic risk assessment for each operation. Provided that the wind farm details are clearly marked on the appropriate aeronautical charts they do not pose any significant impediment to the helicopter operations. During the day wind turbines are large visible obstacles to be avoided. At night, operations generally remain clear of the wind farm area. The helicopters are equipped with vision enhancement equipment which may permit them to operate in close proximity to the turbines at night. Given the proximity to YWKB and the turbine height, the Chief Pilot strongly suggests that they need obstacle lighting. Normal red obstacle lighting, including Red LED lights (operating in the 655 t0 930 nanometre wavelength range), is suitable for night vision enhancement equipment to provide the pilot with sufficient visibility.

5.11.3 State Aircraft Unit

The Victorian State Aircraft Unit (SAU) is an initiative of the Country Fire Authority (CFA) and the Department of Environment, Land, Water and Planning (DELWP) to provide specialist aviation resources to satisfy firefighting and land management objectives within the State of Victoria.

When an aircraft is tasked by the SAU the responsibility for the safe operation of that aircraft rests with the Pilot in Command. The pilot will determine the level of risk posed by the weather, terrain, obstacles (trees, powerlines, and houses) and specific hazards associated with aerial firefighting or other specialist low flying operations.

5.12 Firefighting

“It is important to remember that aircraft alone do not extinguish fires.”12

Concern about the inability to utilise aerial firefighting in the wind farm area was expressed by some stakeholders. From previous work undertaken by Ambidji regarding firefighting within wind farms it is noted that the rural firefighting agencies in

12 NSW Rural Fire Service submission to the Senate Select Committee on Wind Turbines, 6 March 2015, page 2

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Victoria, New South Wales, South Australia, and Western Australia all view wind turbines and wind farms to be ‘just another hazard’ that has to be considered in the

risk management process associated with aerial firefighting13.

The State rural firefighting agencies made submissions to the recent Senate Select Committee on Wind Turbines. All these submissions attached the Australian Fire and Emergency Service Authorities Council (AFAC) Wind Farms and Bushfire Operations Position Paper 30 October 2014 document. A copy of this paper is

at Appendix E.

The AFAC paper states:

“Aerial firefighting operations will treat the turbine towers similar to other tall obstacles. Pilots and Air Operations Managers will assess these risks as part of routine procedures. Risks due to wake turbulence and the moving blades should also be considered. Wind turbines are not expected to pose unacceptable risks.”14

All these agencies make the point that firefighting aircraft operate to the Visual Flight Rules so can only operate during daylight hours and must remain clear of smoke in order to maintain the required visibility of the ground and obstacles such as trees, power lines, radio masts, houses and ground based fire fighters. The Victorian Country Fire Authority (CFA) comments that:

“… … Fire suppression aircraft operate under the ‘Visual Flight Rules’. As such, fire suppression aircraft only operate in areas where there is no smoke and during daylight hours. Wind turbines, similar to high voltage transmission lines, are a part of the landscape and would be considered in the incident action plan.”15

The South Australian Country Fire Service has published a fact sheet titled Understanding Aerial Firefighting which explains the use and limitations of aircraft in firefighting. The major point made is that:

“The popular perception amongst much of the population is that aircraft alone can put out bushfires. This is not true. CFS firefighters and fire appliance for the vast majority of instances are the primary and only method of controlling bushfires.16”

13 Expert opinion formed by the author from previous QRA work 14 AFAC Wind Farms and Bushfire Operations Position version 2.0 30 October 2014, page 2 15 CFA Emergency Management Guidelines for Wind Energy Facilities May 2015 section 2 16 SA CFS Fact Sheet 10-01, Understanding Aerial Firefighting, March 2015

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A further point made by the CFS is that firefighting aircraft are a limited resource and are not routinely allocated to every fire. A copy is at Appendix F.

From previous work done regarding firefighting within wind farms it is noted that the rural fire fighting agencies in Victoria, New South Wales, South Australia, and Western Australia all make the point that access for fire trucks and personnel, and consequently their ability to fight the fire within a wind farm, is greatly enhanced by the access roads built for the construction and maintenance of the turbines. These roads also act as fire breaks which will slow or contain the fire spread across the open ground. The area around the base of each tower is kept clear of vegetation and as such offers a refuge for fire fighters and their vehicles.

5.13 Topography and Marginal Weather Considerations

Warracknabeal aerodrome elevation is 397ft and Horsham aerodrome elevation is 445ft. The surrounding area is generally flat open plains country with the nearest high ground being Mt Arapiles at 1150ft and 30km to the west south west of Horsham.

There are a number of significant obstacles across this generally open plains country. High voltage power lines, which pose a significant threat to low flying aircraft caught in marginal VMC weather, exist in the vicinity of Horsham and Warracknabeal and traverse the MWWF site. Additionally there are two radio transmission towers near Horsham; one of which is 1096ft (656m) high. See extract of WAC 3469 Hamilton at Appendix G.

Aircraft operating under Instrument Flight Rules (IFR) can operate in poor weather conditions and in cloud which precludes visual acquisition of obstacles and terrain. These operations are protected from obstacles and terrain by PANS OPS surfaces and LSALT’s that are designed to keep the aircraft well above obstacles and terrain.

Otherwise CAR 157 states (in part) that an aircraft operating under VFR must not fly lower than 152m/500ft over a non-populated area being terrain or obstacles on that terrain and within, for an aircraft other than a helicopter, 600m horizontally and, in the case of a helicopter, 300m horizontally to the same, unless:

Due stress of weather or any other avoidable cause it is essential that a lower height be maintained; or

It is engaged in approved low flying private or aerial work; or

It is engaged in flying training and flies over part of a flying training area in respect of which low flying is authorised by CASA under sub regulation 141(1); or

It is undertaking a baulked approach; or

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It is flying in the course of actually taking-off or landing at an aerodrome.

In this regard, the Aeronautical Information Publication (AIP) states that a pilot of a fixed wing aircraft operating under VFR (by day in Class G airspace17) must have 5km forward visibility and remain clear of clouds and in sight of ground or water when operating below 3000ft AMSL. Helicopters are approved in the regulations to operate with 800m visibility if operating at a reduced speed.

In regard to the first bullet point above it is possible that due to lowering cloud base, and if through poor airmanship the aircraft had pressed on to the point that it was unable to execute a turn and fly away from the weather, an aircraft could find itself lower than 152m/500ft above the terrain or obstacles.

The MWWF will be highly visible by day due to the size and colour of the turbines. The Henty Highway is an easily distinguishable landmark that can be followed at low level safely clear of the MWWF.

5.14 NASF Guidelines

The National Airports Safeguarding Framework – Guideline D Managing the Risk to Aviation Safety of Wind Turbine Installations (Wind Farms)/Wind Monitoring Towers provides guidance for the siting and marking of the turbines and meteorological monitoring towers associated with wind farms.

5.14.1 Notification to Authorities

Paragraph 20 of Guideline D advises that:

When wind turbines over 150m above ground level are to be built within 30km (16.2nm) of a certified or registered aerodrome, the proponent should notify the Civil Aviation Safety Authority and Airservices. If the wind farm is within 30km of a military aerodrome, Defence should be notified.

The turbines and meteorological monitoring towers used in the MWWF must be reported to CASA and the RAAF in accordance with AC 139-08(1) Reporting of Tall Structures.

The turbines are greater than 150m and are within 30km (16.2nm) of YWKB so should be considered as a hazardous object.

17 Class G: IFR and VFR flights are permitted and do not require an airways clearance. IFR flights must communicate with air traffic control and receive traffic information on other IFR flights and a flight information service. VFR flights receive a flight information service on request.

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5.14.2 Risk Assessment

The NASF Guideline has the following requirements for a risk assessment.

26. Following preliminary assessment by an aviation consultant of potential issues, proponents should expect to commission a formal assessment of any risks to aviation safety posed by the proposed development. This assessment should address any issues identified during stakeholder consultation.

The preliminary risk assessment for the MWWF indicates that the overall risk to aviation is LOW, however the height and proximity of turbines to YWKB indicates a MEDIUM risk unless mitigators are applied to reduce the risk to LOW. A risk assessment of LOW indicates that the wind farm is ‘not a hazard to aircraft safety’.

27. The risk assessment should address the merits of installing obstacle marking or lighting. The risk assessment should determine whether or not a proposed structure will be a hazardous object. CASA may determine, and subsequently advise a proponent and relevant planning authorities that the structures have been determined as:

(a) Hazardous but that the risks to aircraft safety would be reduced by the provision of approved lighting and/or marking; or

(b) Hazardous and should not be built, either in the location and/or to the height proposed as an unacceptable risk to aircraft safety will be created; or

(c) Not a hazard to aircraft safety.

The 722ft (220m) tip height of the turbines and their proximity, 5.07nm (9.39km), to YWKB means the turbines could be considered as hazardous objects and pose a MEDIUM risk to aviation activity at the aerodrome.

To mitigate the hazard described above, the turbines closest to YWKB will need to be appropriately marked and lit.

With the turbines closest to YWKB appropriately marked and lit they will comply with part a), whereby they are “hazardous but that the risks to aircraft safety would be reduced by the provision of approved lighting and/or marking.”

28 If CASA advice is that the proposal is hazardous and should not be built, planning authorities should not approve the proposal. If a wind turbine will penetrate a PANS-OPS surface, CASA will object to the proposal. Planning decision makers should not approve a wind turbine to which CASA has objected.

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The MWWF does not penetrate the OLS for either YWKB or YHSM. It is proposed that the 10nm MSA for YWKB be raised to 2200ft and that the YWKB RWY 08 RNAV-Z procedure be modified.

Once this is achieved the MWWF will not penetrate the PANS-OPS surfaces for YWKB or YHSM.

29 In the case of military aerodromes, Defence will conduct a similar assessment to the process described above if required. Airservices, or in the case of a military aerodrome, Defence, may object to a proposal if it will adversely impact on Communications, Navigation or Surveillance (CNS) infrastructure. Airservices/ Defence will provide detailed advice to proponents on request regarding the requirements that a risk assessment process must meet from the CNS perspective.

There is no military or civil CNS infrastructure that will be impacted by the MWWF.

5.14.3 Lighting of Wind Turbines in the Vicinity of an Aerodrome

31 Siting of wind turbines in the vicinity of an aerodrome is strongly discouraged, as these tall structures can pose serious hazards to aircraft taking off and landing. Where a wind turbine is proposed that will penetrate the OLS of an aerodrome, the proponent should conduct a risk assessment. The risk assessment to be conducted by a suitably qualified person, should examine the effect of the proposed wind turbines on the operation of aircraft. The study should be made available to CASA to assist assessment of any potential risk to aviation safety.

The MWWF does not penetrate the OLS for either YWKB or YHSM. It proposed that the 10nm MSA for YWKB be raised to 2200ft and that the YWKB RWY 08 RNAV-Z procedure is modified.

Once this is achieved the MWWF will not penetrate the PANS-OPS surfaces for YWKB or YHSM.

32 CASA may determine that the proposal is:

(a) Hazardous and should not be built, either in the location and/or to the height proposed, as an unacceptable risk to aircraft safety will be created; or

(b) Hazardous, but that the risks to aircraft safety would be reduced by the provision of approved lighting and/or marking.

With the turbines closest to YWKB lit with aviation obstruction lights they will comply

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with part (b), whereby they are “hazardous but that the risks to aircraft safety would be reduced by the provision of approved lighting.”

5.15 QRA Findings

Risk Element Assessed

Level of Risk

Comment

Airport Operations LOW Warracknabeal LOW Mitigated by Obstacle Lighting Horsham LOW Aircraft Landing Area Operations LOW Pilot responsibility. None identified in area Known Highly Trafficked Routes LOW None identified in the area Published Air Routes LOW Nil impact Restricted Airspace LOW Nil in the area Promulgated Flying Training Areas LOW Nil in the area Night Flying LOW Emergency Services Flying LOW Commercial Flying LOW Recreational and Sport Aviation LOW By day only Recreational Pilot Training (RA-AUS) LOW By day only GA Flying LOW GA Pilot Training LOW Weather and Topographical Issues LOW

Table 5.15.1 – Risk Summary

The Murra Warra Wind Farm will not be a hazard to aircraft safety by day and by night when recommended mitigation is provided. Refer table 5.15.1 above.

The wind farm must report to aviation authorities in accordance with AC 139-08(0) Reporting of Tall Structures and marked on the appropriate aeronautical charts.

Additionally, formal notification of the location and height of the MWWF should be made to:-

Local aviation operators;

Local Aerial Agricultural Applications Operators at Nhill, Derrinallum, Stawell, Ballarat and Warrnambool;

Victorian Police Air Wing;

Victorian Air Ambulance;

The State Air Desk;

Aerial Agricultural Association of Australia (AAAA);

Gliding Federation Australia (GFA) and

Recreational Aviation Australia (RA-Aus).

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As described in paragraph 5.1.3 above YWKB requires Obstacle Lighting on some of the MWWF turbines to mitigate the risk to night operations of aircraft at the aerodrome.

It is considered that once the mitigations outlined above have been put in place, the risk to aircraft safety is acceptable and the MWWF will not be a hazard to aircraft safety and therefore “not of operational significance” to aircraft operations.

6. OBSTACLE LIGHTING REVIEW

6.1 Summary of International Standards for Obstacle Lighting of Wind Farms

6.1.1 International Civil Aviation Organisation

The relevant International Civil Aviation Organisation (ICAO) recommendations regarding wind farms are detailed in Annex 14 – Aerodromes.18

ICAO has recommended that a wind turbine shall be marked and/or lit if it is determined to be an obstacle. Section 4.3 of the Annex refers to “Objects outside the Obstacle Limitation Surface” and Section 4.3.2 in particular states inter-alia: -

4.3.2 Recommendation – In areas beyond the limits of the obstacle limitation surfaces, at least those objects which extend to a height of 150m or more above ground level should be regarded as obstacles, unless a special aeronautical study indicates that they do not constitute a hazard to aeroplanes.

Note – This study may have regard to the nature of operations concerned and may distinguish between day and night operations.

6.2.4 Wind Turbines

Markings

6.2.4.1 A wind turbine shall be marked and/or lit if it is determined to be an obstacle.

Note – See 4.3.1 and 4.3.2

6.2.4.2 Recommendation – The rotor blades, nacelle and upper 2/3 of the supporting mast of wind turbines should be painted white, unless otherwise indicated by an aeronautical study.

18 ICAO Annex 14 Aerodromes Vol 1 Aerodrome Design and Operations Sixth Edition 14 November 2013

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Lighting

6.2.4.3 Recommendation – When lighting is deemed necessary, medium-intensity obstacle lights should be used. In the case of a wind farm, i.e. a group of 2 or more wind turbines, it should be regarded as an extensive object and the lights should be installed

a) to identify the perimeter of the wind farm;

b) respecting the maximum spacing, in accordance with 6.2.3.15*, between the lights along the perimeter, unless a dedicated assessment shows a greater spacing can be used;

c) so that, where flashing lights are used, they flash simultaneously; and

d) so that, within a wind farm, any wind turbines of significantly higher elevation are also identified wherever they are located.

6.2.4.4 Recommendation – The obstacle lights should be installed on the nacelle in such a manner as to provide an unobstructed view for aircraft approaching from any direction.

*6.2.3.15 recommends medium intensity lights be spaced at longitudinal intervals not exceeding 900m.

6.1.2 Other International Aviation Regulatory Authorities

A review of the standards and recommendations regarding wind farms as obstacles from several countries, including the US FAA, CAA UK, CAA NZ, Transport Canada and the Irish Aviation Authority shows that wind turbines shall be painted white or off-white so that they contrast with the surrounding landscape unless a risk assessment indicates a different colour should be used.

The review also shows there is a wide variation as to the determining criteria related to the location, height and spacing of wind turbines that should be lit. A number of countries are now taking into account the visual amenity associated with required obstacle lighting of wind farms by assessing the hazard to aviation safety posed by its nature and location. In essence, a wind farm is required to be lit unless a risk assessment shows that it is not a hazard to aviation safety.

Several countries, including Canada, Norway and the USA have approved the use of radar based Obstacle Collision Avoidance Systems (OCAS)19 to activate obstacle lighting in the presence of an aircraft. This system allows the obstacle lighting to be in a quiescent state until activated by the system sensing the presence of an aircraft.

Throughout the world the accepted obstacle marking for wind turbines is to paint them white or off-white so that they contrast to the surrounding landscape and where a risk

19 OCAS technology is now owned by Vestas; see http://www.ocas-as.no/us/

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assessment considers them to be a hazard to aviation they shall be lit at night.

6.2 Australian regulatory framework for Obstacle Lighting of Wind Farms

CASA is Australia’s aviation safety regulator and is responsible for setting standards applicable to the protection of airspace and the safety of aircraft and airport operations. Australia, as a member state, applies the ICAO Standards and Recommended Practices to Australian aviation except where it formally lodges a “difference.”

CASA issued Advisory Circular AC139-18 (0) Obstacle Marking of Wind Farms in July 2007. CASA withdrew this AC in October 2008 after consideration of its legality and complaints to CASA’s Industry Complaints Commissioner.

In a letter from CASA, dated February 2013 and titled Current Civil Aviation Safety Authority (CASA) approach to the impact of tall structures, including wind turbines and wind monitoring masts on aviation the following statement is made:

CASA has no specific authority to require action for the obstacle marking and lighting of tall structures, including Wind Turbines and Monitoring Masts, located away from certified, registered or certain other aerodromes (regulated aerodromes). CASA cannot impose a requirement for the provision of obstacle lights, nor can CASA comment on the location or design of tall structures that are located away from the vicinity of a regulated aerodrome.

Not withstanding CASA’s regulatory authority, owners of structures which could be hazardous to aviation may have a duty of care to aviators. Wind monitoring towers erected as part of the wind farm development are normally tall slender skeletal structures which can be near invisible to pilots of low flying aircraft.

A copy of this letter is at Appendix H

6.2.1 Civil Aviation Safety Regulations

The Civil Aviation Safety Regulations (CASR) Part 139 Section E contains the regulations governing obstacles. These regulations are applicable to the protection of airspace and aircraft operations in the vicinity of aerodromes. They are not applicable to obstacles that are beyond the vicinity of aerodromes.

6.2.2 National Airports Safeguarding Framework

The Australian National Airports Safeguarding Advisory Group (NASAG) produced a set of guidelines called the National Airports Safeguarding Framework (NASF) in 2012.

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The purpose of the National Airports Safeguarding Framework (the Safeguarding Framework) is to enhance the current and future safety, viability and growth of aviation operations at Australian airports, by supporting and enabling:

the implementation of best practice in relation to land use assessment and decision making in the vicinity of airports;

assurance of community safety and amenity near airports;

better understanding and recognition of aviation safety requirements and aircraft noise impacts in land use and related planning decisions;

the provision of greater certainty and clarity for developers and land owners;

improvements to regulatory certainty and efficiency; and

the publication and dissemination of information on best practice in land use and related planning that supports the safe and efficient operation of airports.

Guideline D Managing the Risk of Wind Turbine Farms as Physical Obstacles to Air Navigation provides information regarding wind farms. This guideline provides the following information: -

20 When wind turbines over 150m above ground level are to be built within 30km (16.2nm) of a certified or registered aerodrome, the proponent should notify the Civil Aviation Safety Authority and Airservices. If the wind farm is within 30km of a military aerodrome, Defence should be notified.

Lighting of wind turbines in the vicinity of an aerodrome

31 Siting of wind turbines in the vicinity of an aerodrome is strongly discouraged, as these tall structures can pose serious hazards to aircraft taking off and landing. Where a wind turbine is proposed that will penetrate the OLS of an aerodrome, the proponent should conduct a risk assessment. The risk assessment to be conducted by a suitably qualified person, should examine the effect of the proposed wind turbines on the operation of aircraft. The study should be made available to CASA to assist assessment of any potential risk to aviation safety.

32 CASA may determine that the proposal is:

(a) Hazardous and should not be built, either in the location and/or to the height proposed, as an unacceptable risk to aircraft safety will be created; or

(b) Hazardous, but that the risks to aircraft safety would be reduced by the provision of approved lighting and/or marking.

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6.3 Obstacle Lighting Summary

The MWWF does not penetrate the OLS for either YWKB or YHSM. When the 10nm MSA for YWKB is raised to 2200ft and the YWKB RWY 26 RNAV (GNSS) Approach is modified the MWWF does not penetrate any PANS-OPS surfaces.

ICAO recommends in areas beyond the limits of the obstacle limitation surfaces, at least those objects which extend to a height of 150m or more AGL should be regarded as obstacles, unless a special aeronautical study indicates that they do not constitute a hazard to aeroplanes.

The NASF Guideline D recommends that any structure of 150m or taller AGL be notified to CASA.

CASR 139.365 requires any structure 110m or taller AGL to be notified to CASA.

The MWWF turbines have a tip height of 220m AGL and therefore can be regarded as an obstacle and be subject to a Risk Assessment to ascertain whether they constitute a hazard to aviation safety.

The size and colour of the turbines is considered suitable marking by day. Their proximity to YWKB is considered to be a hazard to night flying at that aerodrome. This risk can be mitigated to an acceptable level by the installation of obstacle lighting on the line of perimeter turbines from T250, T258, T255, T256, T257 and T254. If LED obstruction lighting is used the LED light emitted must be in the 655 to 930 nanometre wavelength range to facilitate the effective use of night vision devices in aircraft.

To maintain the visual amenity of the area at night these lights should be activated by a PAL system operating on the same frequency as the PAL at YWKB. This will ensure the obstacle lights illuminate when the PAL at YWKB is activated for night operations at the aerodrome.

7. WIND MONITORING TOWERS

Meteorological Monitoring Masts are very difficult to see due to their slender construction and guy wires. The masts are often a grey (galvanised steel) colour that readily blends with the background.

The photograph in Fig 7.1 below shows a Meteorological Monitoring Mast as seen from the ground.

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Figure 7.1 – A Meteorological Monitoring Mast photographed from the ground

7.1 NASAG Guideline – Marking of Meteorological Monitoring Masts

The NASAG guideline also refers to the marking and lighting of wind monitoring towers. The relevant points are summarised as:

Wind monitoring towers are very difficult to see from the air due to their slender construction and guy wires. This is a particular problem for low flying aircraft, particularly aerial agricultural and emergency services operations.

Measures to be considered to improve visibility include:

The top one third of wind monitoring towers be painted in alternating contrasting bands of colour. Examples can be found in the CASA MOS 139 sections 8 and 9;

Marker balls, high visibility flags or high visibility sleeves placed on the outer guy wires;

Ensuring the guy wire ground attachment points have contrasting colours to the surrounding ground and vegetation; or

A flashing strobe light during daylight hours.

7.2 Federal Aviation Administration – Marking of MET towers

It is noted that the Federal Aviation Administration (FAA) has issued, on 24th June 2011, guidance material for the marking of Meteorological Evaluation Towers (METS) of less than 200ft (61m) in height to enhance visibility to low flying aircraft. The FAA recommends that the entire tower be painted in alternating contrasting bands of colour,

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the guy wires have high visibility balls or sleeves and that the markings are replaced when faded or otherwise deteriorated.20

7.3 Recommendation

It is recommended that RES ensure the wind monitoring towers used in the MWWF are:

Appropriately marked with marker balls or high visibility flags or sleeves on the guy wires;

Reported as tall structures in accordance with AC139-08;

Are notified to local aviation operators at Horsham, Warracknabeal;

Are notified to local aerial agricultural operators at Nhill; and

Are notified to the Aerial Agricultural Association of Australia.

8. CONCLUSIONS

8.1 AIS

The Murra Warra Wind Farm development will NOT impact upon the following:

The OLS published for any registered or certified aerodrome;

The operation of any Navigation Aids and Communication facilities; and

The operation of any Airspace Surveillance facility.

However the Wind Farm WILL impact upon the following:

The 10 nm Minimum Sector Altitude (MSA) for Warracknabeal Aerodrome;

The RWY 08 RNAV-Z approach for Warracknabeal Aerodrome.

Mitigation actions to minimise or avoid the above impacts have been discussed in the relevant sections of the AIS, and are summarised as follows:

The 10nm MSA for Warracknabeal to be increased from 1700ft to 2200ft;

20 NAAA (US) website http://www.agaviation.org/content/faa-releases-guidance-marking-met-towers accessed 27/05/2014

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The Warracknabeal RWY 08 RNAV-Z approach to be modified to provide standard Minimum Obstacle Clearance (MOC) in the sector over the Wind Farm Area.

Requests to increase the Warracknabeal 10nm MSA and to modify the RWY 08 RNAV-Z Procedure will need to be considered by AsA, The Airport Group and CASA for approval.

8.1.1 AsA Response to AIS

AsA provided the following advice: -

MWWF will not impact on any CNS;

MWWF will not impact on YHSM OLS and PANS-OPS;

MWWF will not impact on any LSALT

YWKB 10nm MSA can be raised.

8.1.2 Defence Response to AIS

The Department of Defence advises that they have no objection to the proposed development at a maximum tip height of 354.44m AHD. They remind RES Australia of their responsibility to report tall structures in accordance with AC 139-08 – Reporting of Tall Structures.

Defence also advise that “… … should LED obstruction lighting be required for these turbines, the frequency of the LED light emitted must fall within the range of wavelengths 655 to 930 nanometres. This frequency range would be visible to aircrews, operating in or through the area using night vision devices.”

8.2 Risk Assessment

The risk assessment of the MWWF shows that, with the provision of obstacle lighting on the line of turbines creating the northern arc of the wind farm, it will not be a hazard to aircraft safety and therefore “not of operational significance” to aircraft operations.

8.3 Obstacle Lighting

This QRA indicates that, with the addition of obstacle lighting on the arc of turbines along the northern end of the wind farm, the MWWF is “not a hazard to aircraft safety.”

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To maintain the visual amenity of the area it is recommended that the obstacle lighting on the arc of turbines along the northern end of the wind farm be activated by a Pilot Activated Lighting system operating on the same frequency as that for YWKB airport lighting.

8.4 Reporting of Tall Structures

The turbines proposed for the MWWF have a tip height of 220m (722ft) AGL; therefore they need to be reported to CASA in accordance with MOS 139 paragraph 7.1.5.2 for assessment as an obstacle.

CASR 139.365 required the turbines and the meteorological monitoring masts to be reported as tall structures in accordance with AC 139-08(0) for inclusion on appropriate aeronautical charts.

The reporting of tall structures includes the wind monitoring towers (see Section 7).

8.5 Rationale for Partial Obstacle Lighting

Generally it is considered that the full perimeter and the tallest point of a wind farm should be lit if it is assessed as hazardous to aircraft safety. Given that only the six turbines at the northern end of the wind farm comprising 116 turbines, are assessed as hazardous to aircraft safety at night, by virtue of their proximity to YWKB it is considered unnecessary to light the entire wind farm.

None of the turbines penetrate the YWKB OLS and once the 10nm MSA and RWY 08 RNAV-Z Procedure are modified, the PANS-OPS surfaces will not be penetrated. The closest turbine T257, to YWKB will be 5.07nm from the ARP at the aerodrome and is therefore outside the 3nm circling area and definitely beyond the circuit area. At a height of 220m (722ft) AGL it is considered that this turbine is an obstacle that may be hazardous to aircraft operations at the aerodrome. To mitigate this hazard the turbine needs to be appropriately marked and lit.

By day all the turbines are appropriately marked by virtue of their size and white colour. At night turbine T257 requires obstacle lighting to ensure its visibility to aircraft operating at YWKB.

In order to indicate to pilots that T257 is not a lone obstacle it will be necessary to light the line of turbines comprising T257, T256, T255 and T258 which form the northern boundary of the MWWF. To further delineate the extent of the wind farm at night the turbine on the west side, T250 and the turbine on the east side, T254 should also be lit. This will provide sufficient indication that there is an extensive obstacle in the vicinity of YWKB.

In order to maintain visual amenity of the area at night it is recommended that the lighting of these turbines be activated by a PAL system operating on the same frequency as the aerodrome lighting at YWKB. This will ensure that these turbines illuminate as an obstacle associated with the aerodrome for night VFR and IFR arrivals and departures.

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9. DUTY OF CARE

As a part of corporate responsibility and duty of care, it is appropriate for the proponent to formally advise all relevant stakeholders of:

the locations and heights of the turbines and meteorological masts and when they would be constructed or decommissioned; and

the developer’s intentions regarding marking and lighting of the wind farm turbines.

RES Australia’s attention is also drawn to the following determination of the New South Wales Court of Appeal, in the case of Sheather vs Country Energy, where, inter-alia, the court determined the following.21

“Mr Sheather, the owner of the helicopter which crashed into a Country Energy owned spur line while flying well below the mandatory height regulations for aircraft, appealed an earlier decision on the grounds that Country Energy had failed to provide sufficient warning of the spur line. Despite Country Energy observing all legal compliance requirements, the NSW Court of Appeal held that Country Energy owed a duty of care to pilots and aircraft owners and had breached its duty of care.”

Due cognisance of this decision should be taken by RES Australia and its legal and insurance advisors in considering this report.

21 Sheather v Country Energy [2007] NSWCA 179

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16 June 2016 Commercial-In-Confidence Appendix A

APPENDIX A

Airservices Australia Aviation Assessments for Wind Farm Developments

19th August 2014

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APPENDIX A

THE GROUP AMBIDJI

16 June 2016 Commercial-In-Confidence Appendix B

APPENDIX B

Murra Warra Wind Farm Site Identification, Coordinates and Elevations

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Turbine ID

X Y Z Longitude Latitude Turbine Tip AHD m

Turbine Tip AHD ft

T13 618601.00 5963999.00 129.47 E142° 19' 25.14" S036° 27' 43.00" 349.97 1149T14 615376.00 5963992.00 130.56 E142° 17' 15.60" S036° 27' 44.64" 351.06 1152T15 615826.00 5963992.00 132.75 E142° 17' 33.68" S036° 27' 44.45" 353.25 1159T16 616276.00 5963992.00 131.73 E142° 17' 51.75" S036° 27' 44.25" 352.23 1156T17 616726.00 5963992.00 133.21 E142° 18' 09.83" S036° 27' 44.05" 353.71 1161T19 618029.00 5963996.00 132.35 E142° 19' 02.17" S036° 27' 43.35" 352.85 1158T21 615376.00 5964532.00 130.52 E142° 17' 15.31" S036° 27' 27.12" 351.02 1152T22 615826.00 5964532.00 131.59 E142° 17' 33.39" S036° 27' 26.93" 352.09 1156T23 616276.00 5964532.00 131.79 E142° 17' 51.46" S036° 27' 26.73" 352.29 1156T28 613485.00 5965072.00 130.14 E142° 15' 59.07" S036° 27' 10.41" 350.64 1151T29 613963.00 5965072.00 130.23 E142° 16' 18.27" S036° 27' 10.21" 350.73 1151T30 614476.00 5965072.00 130.11 E142° 16' 38.88" S036° 27' 09.99" 350.61 1151T31 614926.00 5965072.00 130.56 E142° 16' 56.95" S036° 27' 09.79" 351.06 1152T32 615376.00 5965072.00 130.37 E142° 17' 15.02" S036° 27' 09.60" 350.87 1152T33 615826.00 5965072.00 130.65 E142° 17' 33.10" S036° 27' 09.40" 351.15 1153T40 613484.00 5965612.00 129.74 E142° 15' 58.75" S036° 26' 52.89" 350.24 1150T41 613963.00 5965612.00 129.48 E142° 16' 17.99" S036° 26' 52.69" 349.98 1149T42 614476.00 5965612.00 129.16 E142° 16' 38.59" S036° 26' 52.47" 349.66 1148T43 614926.00 5965612.00 128.56 E142° 16' 56.66" S036° 26' 52.27" 349.06 1146T44 615376.00 5965612.00 128.57 E142° 17' 14.73" S036° 26' 52.08" 349.07 1146T50 613484.00 5966141.00 129.56 E142° 15' 58.47" S036° 26' 35.73" 350.06 1149T51 613963.00 5966141.00 128.66 E142° 16' 17.70" S036° 26' 35.52" 349.16 1146T52 614476.00 5966152.00 128.73 E142° 16' 38.30" S036° 26' 34.95" 349.23 1146T53 614926.00 5966152.00 128.31 E142° 16' 56.37" S036° 26' 34.75" 348.81 1145T54 615376.00 5966152.00 128.81 E142° 17' 14.44" S036° 26' 34.56" 349.31 1147T58 620755.00 5968829.00 126.93 E142° 20' 48.95" S036° 25' 05.32" 347.43 1140T59 621205.00 5968829.00 127.01 E142° 21' 07.02" S036° 25' 05.11" 347.51 1141T65 614476.00 5966728.00 128.04 E142° 16' 37.99" S036° 26' 16.26" 348.54 1144T66 614926.00 5966733.00 128.50 E142° 16' 56.06" S036° 26' 15.90" 349.00 1146T67 615376.00 5966729.00 127.86 E142° 17' 14.13" S036° 26' 15.84" 348.36 1143T69 620280.00 5968829.00 127.00 E142° 20' 29.89" S036° 25' 05.53" 347.50 1141T74 614926.00 5967332.00 128.44 E142° 16' 55.74" S036° 25' 56.46" 348.94 1145T75 619434.00 5968828.00 126.63 E142° 19' 55.92" S036° 25' 05.94" 347.13 1139T76 619830.00 5968829.00 126.92 E142° 20' 11.82" S036° 25' 05.73" 347.42 1140T82 618201.00 5968644.00 128.43 E142° 19' 06.52" S036° 25' 12.46" 348.93 1145T83 618730.00 5968644.00 127.21 E142° 19' 27.76" S036° 25' 12.23" 347.71 1141T85 614973.00 5968482.00 128.40 E142° 16' 57.02" S036° 25' 19.13" 348.90 1145

MURRA WARRA WIND FARM TURBINE IDs COORDINATES AND ELEVATIONSTURBINE TIP AHD m INCLUDES 0.5 m ACCURACY CORRECTION & 220 m TIP AGL

TURBINE IDs ARE NOT CONSECTUTIVELY NUMBERED

APPENDIX B

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Turbine ID

Turbine Tip AHD ft

T101 617176.00 5963992.00 133.94 E142° 18' 27.91" S036° 27' 43.86" 354.44 1163T102 612584.00 5966152.00 129.53 E142° 15' 22.32" S036° 26' 35.75" 350.03 1149T103 612584.00 5965612.00 130.07 E142° 15' 22.60" S036° 26' 53.27" 350.57 1151T104 612584.00 5965073.00 130.04 E142° 15' 22.88" S036° 27' 10.76" 350.54 1151T107 619380.00 5968289.00 127.43 E142° 19' 54.05" S036° 25' 23.46" 347.93 1142T108 619830.00 5968289.00 127.11 E142° 20' 12.12" S036° 25' 23.25" 347.61 1141T109 620280.00 5968289.00 127.82 E142° 20' 30.19" S036° 25' 23.05" 348.32 1143T110 620755.00 5968289.00 127.99 E142° 20' 49.26" S036° 25' 22.84" 348.49 1144T114 619830.00 5967749.00 128.19 E142° 20' 12.42" S036° 25' 40.77" 348.69 1144T115 620280.00 5967749.00 127.76 E142° 20' 30.49" S036° 25' 40.57" 348.26 1143T116 620750.00 5967749.00 127.38 E142° 20' 49.36" S036° 25' 40.36" 347.88 1142T120 619978.00 5967146.00 128.24 E142° 20' 18.70" S036° 26' 00.27" 348.74 1145T145 619051.00 5964000.00 129.28 E142° 19' 43.22" S036° 27' 42.76" 349.78 1148T151 615423.00 5968484.00 128.41 E142° 17' 15.08" S036° 25' 18.87" 348.91 1145T152 615873.00 5968484.00 128.19 E142° 17' 33.15" S036° 25' 18.68" 348.69 1144T153 616323.00 5968484.00 128.94 E142° 17' 51.21" S036° 25' 18.48" 349.44 1147T154 616773.00 5968484.00 131.86 E142° 18' 09.28" S036° 25' 18.28" 352.36 1157T155 617223.00 5968484.00 132.40 E142° 18' 27.35" S036° 25' 18.09" 352.90 1158T156 615423.00 5967885.00 127.64 E142° 17' 15.40" S036° 25' 38.31" 348.14 1143T157 615873.00 5967944.00 128.23 E142° 17' 33.44" S036° 25' 36.20" 348.73 1145T158 616323.00 5967944.00 128.68 E142° 17' 51.51" S036° 25' 36.00" 349.18 1146T161 615376.00 5967334.00 127.36 E142° 17' 13.81" S036° 25' 56.21" 347.86 1142T162 615873.00 5967404.00 128.01 E142° 17' 33.73" S036° 25' 53.72" 348.51 1144T190 612584.00 5964533.00 131.26 E142° 15' 23.17" S036° 27' 28.28" 351.76 1155T195 614476.00 5964532.00 130.29 E142° 16' 39.16" S036° 27' 27.51" 350.79 1151T196 614926.00 5964532.00 130.18 E142° 16' 57.24" S036° 27' 27.32" 350.68 1151T198 614926.00 5963992.00 130.43 E142° 16' 57.53" S036° 27' 44.84" 350.93 1152T214 613034.00 5966152.00 129.60 E142° 15' 40.39" S036° 26' 35.56" 350.10 1149T215 613034.00 5965612.00 130.10 E142° 15' 40.67" S036° 26' 53.08" 350.60 1151T216 613034.00 5964533.00 130.78 E142° 15' 41.24" S036° 27' 28.09" 351.28 1153T217 613484.00 5964533.00 131.39 E142° 15' 59.32" S036° 27' 27.90" 351.89 1155T218 613963.00 5964532.00 131.08 E142° 16' 18.56" S036° 27' 27.73" 351.58 1154T219 612134.00 5964533.00 130.38 E142° 15' 05.09" S036° 27' 28.47" 350.88 1152T220 612134.00 5963993.00 130.80 E142° 15' 05.37" S036° 27' 46.00" 351.30 1153T221 612584.00 5963993.00 130.45 E142° 15' 23.45" S036° 27' 45.81" 350.95 1152T222 613034.00 5963993.00 131.15 E142° 15' 41.53" S036° 27' 45.61" 351.65 1154

APPENDIX B

THE GROUP AMBIDJI

(T266 has been removed)

Turbine ID

Turbine Tip AHD ft

T223 613484.00 5963993.00 132.55 E142° 15' 59.60" S036° 27' 45.42" 353.05 1159T224 613963.00 5963992.00 130.02 E142° 16' 18.84" S036° 27' 45.25" 350.52 1150T225 614476.00 5963992.00 130.27 E142° 16' 39.45" S036° 27' 45.03" 350.77 1151T227 620278.00 5969373.00 127.10 E142° 20' 29.50" S036° 24' 47.88" 347.60 1141T228 620737.00 5969378.00 125.79 E142° 20' 47.92" S036° 24' 47.51" 346.29 1137T229 621179.00 5969377.00 126.33 E142° 21' 05.67" S036° 24' 47.34" 346.83 1138T230 621627.00 5969369.00 127.45 E142° 21' 23.66" S036° 24' 47.40" 347.95 1142T231 622253.00 5969023.00 129.80 E142° 21' 48.98" S036° 24' 58.34" 350.30 1150T232 622705.00 5969019.00 128.04 E142° 22' 07.13" S036° 24' 58.26" 348.54 1144T233 622253.00 5969531.00 128.59 E142° 21' 48.69" S036° 24' 41.86" 349.09 1146T234 622709.00 5969531.00 125.35 E142° 22' 07.00" S036° 24' 41.65" 345.85 1135T235 619837.00 5969917.00 125.89 E142° 20' 11.50" S036° 24' 30.43" 346.39 1137T236 620282.00 5969913.00 126.15 E142° 20' 29.36" S036° 24' 30.36" 346.65 1138T237 620729.00 5969920.00 125.60 E142° 20' 47.30" S036° 24' 29.93" 346.10 1136T238 621182.00 5969913.00 125.93 E142° 21' 05.49" S036° 24' 29.95" 346.43 1137T239 621627.00 5969913.00 126.12 E142° 21' 23.35" S036° 24' 29.75" 346.62 1138T240 622249.00 5970075.00 125.99 E142° 21' 48.23" S036° 24' 24.21" 346.49 1137T241 622717.00 5970059.00 123.82 E142° 22' 07.02" S036° 24' 24.51" 344.32 1130T242 623178.00 5970051.00 123.68 E142° 22' 25.53" S036° 24' 24.56" 344.18 1130T243 623634.00 5970047.00 123.93 E142° 22' 43.83" S036° 24' 24.48" 344.43 1130T244 620345.00 5970611.00 124.19 E142° 20' 31.50" S036° 24' 07.68" 344.69 1131T245 620798.00 5970627.00 124.61 E142° 20' 49.67" S036° 24' 06.96" 345.11 1133T246 621303.00 5970623.00 127.50 E142° 21' 09.94" S036° 24' 06.86" 348.00 1142T247 621773.00 5970607.00 126.37 E142° 21' 28.82" S036° 24' 07.16" 346.87 1139T248 622217.00 5970631.00 124.85 E142° 21' 46.63" S036° 24' 06.18" 345.35 1134T249 622697.00 5970619.00 123.33 E142° 22' 05.90" S036° 24' 06.35" 343.83 1129T250 620381.00 5971191.00 124.98 E142° 20' 32.62" S036° 23' 48.85" 345.48 1134T251 620829.00 5971183.00 126.02 E142° 20' 50.61" S036° 23' 48.90" 346.52 1137T252 621313.00 5971183.00 125.59 E142° 21' 10.03" S036° 23' 48.68" 346.09 1136T253 621785.00 5971178.00 125.60 E142° 21' 28.98" S036° 23' 48.63" 346.10 1136T254 622221.00 5971170.00 126.15 E142° 21' 46.48" S036° 23' 48.69" 346.65 1138T255 620816.00 5971722.00 125.68 E142° 20' 49.78" S036° 23' 31.42" 346.18 1136T256 621308.00 5971722.00 124.30 E142° 21' 09.53" S036° 23' 31.20" 344.80 1132T257 621769.00 5971714.00 123.41 E142° 21' 28.03" S036° 23' 31.25" 343.91 1129T258 620361.00 5971717.00 124.01 E142° 20' 31.53" S036° 23' 31.79" 344.51 1131T259 619900.00 5970619.00 125.04 E142° 20' 13.63" S036° 24' 07.62" 345.54 1134T260 623146.00 5969021.00 125.67 E142° 22' 24.83" S036° 24' 57.99" 346.17 1136T261 623158.00 5969534.00 124.56 E142° 22' 25.02" S036° 24' 41.34" 345.06 1133T262 623608.00 5969527.00 124.78 E142° 22' 43.09" S036° 24' 41.36" 345.28 1133T263 621186.00 5968269.00 128.15 E142° 21' 06.57" S036° 25' 23.29" 348.65 1144T264 621730.00 5968695.00 127.85 E142° 21' 28.17" S036° 25' 09.22" 348.35 1143T265 621727.00 5968152.00 128.29 E142° 21' 28.36" S036° 25' 26.84" 348.79 1145T266 622219.00 5971710.00 124.10 E142° 21' 46.09" S036° 23' 31.17" 344.60 1131

APPENDIX B

THE GROUP AMBIDJI

16 June 2016 Commercial-In-Confidence Appendix C

APPENDIX C

Airservices Australia Response to the AIS

THE GROUP AMBIDJI

APPENDIX C

From: Airport Developments [mailto:Airport.Developments@AirservicesAustralia.com] Sent: Tuesday, 15 March 2016 12:31 PM To: Barrie Slingo Cc: Bruce Robinson; Kevin Garthwaite (Kevin.Garthwaite@res-ltd.com) Subject: AIRSERVICES RESPONSE: Murra Warra Wind Farm - Aviation Impact Statement - 220 m High Turbines (VIC-WF-009 P4) [SEC=UNCLASSIFIED] Hi Barrie, As promised and my sincere apologies for the length of time this has taken. I refer to your request for Airservices assessment of the Murra Warra Wind Farm which is to be located in regional Victoria and has increased its turbine heights since last assessed by Airservices. -- AIRSPACE PROCEDURES -- Warracknabeal aerodrome With respect to procedures designed by Airservices in accordance with ICAO PANS-OPS and Document 9905, at a maximum height of 354.44m (1163ft) AHD the wind farm turbines, as listed in appendix B of the consultants report by The Ambidji Group will affect the following MSA at Warracknabeal aerodrome:

• 10nm minimum sector altitude (MSA). The maximum height of any turbine within the Murra Warra Wind Farm without affecting any procedures at Warracknabeal aerodrome is 218.2m (716ft) AHD however, subject to agreement by the aerodrome operator and CASA, the 10nm MSA could be raised to 2200ft. A permanent NOTAM would be required to increase 10NM MSA from 1700ft to 2200ft. The proponent will need to consult with the aerodrome operator and CASA to secure agreement and to ensure the above change will not adversely impact on the operations of Warracknabeal aerodrome. Horsham aerodrome With respect to procedures designed by Airservices in accordance with ICAO PANS-OPS and Document 9905, at the various heights provided, the wind farm turbines will not affect any instrument sector or circling altitude, nor any instrument approach or departure at Horsham aerodrome. Note: procedures not designed by Airservices at Warracknabeal and Horsham aerodromes were not considered in this assessment. -- CNS FACILITIES -- This proposal for the Murra Warra Wind Farm at the locations provided to a max height of 220m AGL or 354.44m AHD will not adversely impact the performance of any Airservices Precision/Non-Precision Nav Aids, Anemometers, HF/VHF/UHF Comms, A-SMGCS, Radar, PRM, ADS-B, WAM or Satellite/Links. Warm regards Carly Carly Fiumara

THE GROUP AMBIDJI

Airport Development Assistant Corporate and Industry Affairs t 02 6268 4725 | e carly.fiumara@airservicesaustralia.com NOTE: I work part-time from Monday to Wednesday and between the hours of 0730 and 1400. Apologies for any inconvenience. CAUTION: This e-mail is confidential. If you are not the intended recipient, you must not disclose or use the information contained in it. If you have received this e-mail in error, please tell us immediately by return e-mail and delete the document. Airservices Australia does not represent, warrant or guarantee that the integrity of this communication is free of errors, virus or interference.

THE GROUP AMBIDJI

16 June 2016 Commercial-In-Confidence Appendix D

APPENDIX D

Department of Defence Response to the AIS

THE GROUP AMBIDJI

16 June 2016 Commercial-In-Confidence Appendix D

APPENDIX D

THE GROUP AMBIDJI

16 June 2016 Commercial-In-Confidence Appendix E

APPENDIX E

Australian Fire and Emergency Services Authorities Council Wind Farms and Bushfire Operations

THE GROUP AMBIDJI

APPENDIX E

THE GROUP AMBIDJI

16 June 2016 Commercial-In-Confidence Appendix F

APPENDIX F

South Australian Country Fire Service Understanding Aerial Firefighting

THE GROUP AMBIDJI

16 June 2016 Commercial-In-Confidence Appendix F

APPENDIX F

THE GROUP AMBIDJI

16 June 2016 Commercial-In-Confidence Appendix G

APPENDIX G

World Aeronautical Chart (WAC) Hamilton

THE GROUP AMBIDJI

16 June 2016 Commercial-In-Confidence Appendix G

APPENDIX G

WAC 3469 Hamilton 18th Ed Showing Radio Broadcast Tower and High Voltage Power Transmission Lines

High Voltage Power Transmission Lines

Radio Transmitter Tower 656m 1043ft

Radio Transmitter Tower

THE GROUP AMBIDJI

16 June 2016 Commercial-In-Confidence Appendix H

APPENDIX H

CASA Letter February 2013

THE GROUP AMBIDJI

16 June 2016 Commercial-In-Confidence Appendix I

APPENDIX I

Aeronautical Study Glossary

THE GROUP AMBIDJI

APPENDIX G

AERONAUTICAL STUDY GLOSSARY

To facilitate the understanding of aviation terminology used in this report, the following is a glossary of terms and acronyms that are commonly used in aeronautical impact assessments and similar aeronautical studies. A full list of terms and abbreviations used in this report is included in this Appendix. It should be noted that, within aviation, the International standard unit for altitude is feet (ft.) and distance is nautical mile (nm). AC (Advisory Circulars) are issued by CASA and are intended to provide recommendations and guidance to illustrate a means, but not necessarily the only means, of complying with the Regulations.

Aeronautical study is a tool used to review aerodrome and airspace processes and procedures to ensure that safety criteria are appropriate.

AHD (Australian Height Datum) is the datum to which all vertical control for mapping is to be referred. The datum surface is that which passes through mean sea level at the 30 tide gauges and through points at zero AHD height vertically below the other basic junction points. AIP (Aeronautical Information Publication) is a publication promulgated to provide operators with aeronautical information of a lasting character essential to air navigation. It contains details of regulations, procedures and other information pertinent to flying and operation of aircraft. In Australia, the AIP may be issued by CASA or Airservices Australia. Air routes exist between navigation aid equipped aerodromes or waypoints to facilitate the regular and safe flow of aircraft operating under Instrument Flight Rules (IFR).

Airservices Australia is the Australian government-owned corporation providing safe and environmentally sound air traffic management and related airside services to the aviation industry. Altitude is the vertical distance of a level, a point or an object, considered as a point, measured from mean sea level.

AMSL (Above Mean Sea Level) is the elevation (on the ground) or altitude (in the air) of any object, relative to the average sea level datum. In aviation, the ellipsoid known as World Geodetic System 84 (WGS 84) is the datum used to define mean sea level.

ATC (Air Traffic Control) service is a service provided for the purpose of: a. preventing collisions:

1. between aircraft; and

2. on the manoeuvring area between aircraft, vehicles and obstructions; and

b. expediting and maintaining an orderly flow of air traffic.

CASA (Civil Aviation Safety Authority) is the Australian government authority responsible under the Civil Aviation Act 1988 for developing and promulgating appropriate, clear and concise aviation safety standards. As Australia is a signatory to the ICAO Chicago Convention, CASA adopts the standards and recommended practices established by ICAO, except where a difference has been notified.

THE GROUP AMBIDJI

CASR (Civil Aviation Safety Regulations) are promulgated by CASA and establish the regulatory framework (Regulations) within which all service providers must operate.

Civil Aviation Act 1988 (the Act) establishes the CASA with functions relating to civil aviation, in particular the safety of civil aviation and for related purposes.

ICAO (International Civil Aviation Organization) is an agency of the United Nations which codifies the principles and techniques of international air navigation and fosters the planning and development of international air transport to ensure safe and orderly growth. The ICAO Council adopts standards and recommended practices concerning air navigation, its infrastructure, flight inspection, prevention of unlawful interference, and facilitation of border-crossing procedures for international civil aviation. In addition, the ICAO defines the protocols for air accident investigation followed by transport safety authorities in countries signatory to the Convention on International Civil Aviation, commonly known as the Chicago Convention. Australia is a signatory to the Chicago Convention.

IFR (Instrument Flight Rules) are rules applicable to the conduct of flight under IMC. IFR is established to govern flight under conditions in which flight by outside visual reference is not safe. IFR flight depends upon flying by reference to instruments in the flight deck, and navigation is accomplished by reference to electronic signals. It is also referred to as, “a term used by pilots and controllers to indicate the type of flight plan an aircraft is flying,” such as an IFR or VFR flight plan. IMC (Instrument Meteorological Conditions) are meteorological conditions expressed in terms of visibility, distance from cloud and ceiling, less than the minimum specified for visual meteorological conditions.

LSALT (Lowest Safe Altitudes) are published for each low level air route segment. Their purpose is to allow pilots of aircraft that suffer a system failure to descend to the LSALT to ensure terrain or obstacle clearance in IMC where the pilot cannot see the terrain or obstacles due to cloud or poor visibility conditions. It is an altitude that is at least 1,000 feet above any obstacle or terrain within a defined safety buffer region around a particular route that a pilot might fly.

MOS (Manual of Standards) comprises specifications (Standards) prescribed by CASA, of uniform application, determined to be necessary for the safety of air navigation.

NASAG (National Airports Safeguarding Advisory Group) set up in May 2010 to implement the Australian Government’s National Aviation Policy White Paper, Flight Path to the Future initiatives relating to safeguarding airports and surrounding communities from inappropriate development. NASAG comprises representatives from state and territory planning and transport departments, the Civil Aviation Safety Authority (CASA), Airservices Australia, the Department of Defence and the Australian Local Government Association (ALGA) and is chaired by the Department of Infrastructure and Regional Development (DIRD). NASF (National Airports Safeguarding Framework) is the set of guidelines, adopted in July 2012, developed by NASAG to safeguard airports and surrounding communities.

NOTAMs (Notices to Airmen) are notices issued by the NOTAM office containing information or instruction concerning the establishment, condition or change in any aeronautical facility, service, procedure or hazard, the timely knowledge of which is essential to persons concerned with flight operations.

THE GROUP AMBIDJI

Obstacles - All fixed (whether temporary or permanent) and mobile objects, or parts thereof, that are located on an area intended for the surface movement of aircraft or that extend above a defined surface intended to protect aircraft in flight. OLS (Obstacle Limitation Surfaces) are a series of planes associated with each runway at an aerodrome that defines the desirable limits to which objects may project into the airspace around the aerodrome so that aircraft operations may be conducted safely. PANS-OPS (Procedures for Air Navigation Services - Aircraft Operations) is an Air Traffic Control term denominating rules for designing instrument approach and departure procedures. Such procedures are used to allow aircraft to land and take off under Instrument Meteorological Conditions (IMC) or Instrument Flight Rules (IFR). ICAO document 8168-OPS/611 (volumes 1 and 2) outlines the principles for airspace protection and procedure design which all ICAO signatory states must adhere to. The regulatory material surrounding PANS-OPS may vary from country to country.

PANS-OPS Surfaces - Similar to an Obstacle Limitation Surface, the PANS-OPS protection surfaces are imaginary surfaces in space which guarantee the aircraft a certain minimum obstacle clearance. These surfaces may be used as a tool for local governments in assessing building development. Where buildings may (under certain circumstances) be permitted to penetrate the OLS, they cannot be permitted to penetrate any PANS-OPS surface, because the purpose of these surfaces is to guarantee pilots operating under IMC an obstacle free descent path for a given approach.

Prescribed airspace is an airspace specified in, or ascertained in accordance with, the Regulations, where it is in the interests of the safety, efficiency or regularity of existing or future air transport operations into or out of an airport for the airspace to be protected. The prescribed airspace for an airport is the airspace above any part of either an OLS or a PANS OPS surface for the airport and airspace declared in a declaration relating to the airport.

Regulations (Civil Aviation Safety Regulations) VFR (Visual Flight Rules) are rules applicable to the conduct of flight under VMC. VFR allow a pilot to operate an aircraft in weather conditions generally clear enough to allow the pilot to maintain visual contact with the terrain and to see where the aircraft is going. Specifically, the weather must be better than basic VFR weather minima. If the weather is worse than VFR minima, pilots are required to use instrument flight rules.

VMC (Visual Meteorological Conditions) are meteorological conditions expressed in terms of visibility, distance from cloud and ceiling, equal or better than specified minima

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