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Yass Valley Wind Farm Final Report - Peer Review of Aviation Impact Assessments and Consultation Prepared for NSW Department of Planning and Environment 15 September 2014 Reference TAG20140715 The Airport Group – Australian Airports Association Winner 2013 Corporate Project Of The Year Enter Name of Business DOCUMENT VERSION LISTING Version Version Changes/ Actions Staff Date Description 1.0 Initial Draft Preparation of Draft Report JN/CT/MF 25 August 2014 2.1 Final Report – Draft Preparation of Final Report MF 29 August 2014 Update Final Draft Comments 2.2 Final Report and review of entire JN/CT/MT 3 September 2014 document 2.3 Final Report Final Amendments CT/MT 15 September 2014 Yass Valley Wind Farm Independent Peer Review and Consultation – Final Report V2.3 Conducted by The Airport Group – 15 September 2014 2 TABLE OF CONTENTS 1. EXECUTIVE SUMMARY ............................................................................................................... 4 2. BACKGROUND ............................................................................................................................. 5 3. PEER REVIEW ............................................................................................................................. 6 3.1. Methodology and Objectives ........................................................................................................ 6 3.2. Assumptions and Limitations ........................................................................................................ 6 3.3. Analysis ......................................................................................................................................... 6 3.3.1. Desktop Review – Aviation Impact Statement .................................................................... 6 3.3.2. NASAG Guidelines & AsA Aviation Study .......................................................................... 9 3.3.2.1. Area of Identification – 30km or 30nm ........................................................................ 9 3.3.2.2. Communication, Navigation and Surveillance (CNS) ............................................... 10 3.3.2.3. Navigation Aid Identification and Assessment .......................................................... 11 3.3.2.4. Radar ......................................................................................................................... 13 3.3.3. Obstacle Limitation Surfaces (OLS), Private Airstrips and Landing Areas ....................... 17 3.3.4. Guidelines for Aeroplane Landing Areas and PANS-OPS ............................................... 17 3.3.5. Airspace ............................................................................................................................ 19 3.3.5.1. Airspace Classification .............................................................................................. 19 3.3.5.2. CASA & Airservices Australia ................................................................................... 20 3.3.5.3. Airspace User – Class G – Aerial Application ........................................................... 21 3.3.6. Wind Turbines & Meteorological Monitoring Masts ........................................................... 22 3.4. Findings and Recommendations Relating to Reviewed Reports ............................................... 26 4. CONSULTATION ........................................................................................................................ 28 4.1. Methodology and Objectives ...................................................................................................... 28 4.2. Assumptions and Limitations ...................................................................................................... 29 4.3. Analysis ....................................................................................................................................... 29 4.4. Findings and Recommendations Relating to Consultation Undertaken by TAG ........................ 30 5. CONCLUSION ............................................................................................................................ 33 6. ABBREVIATIONS ....................................................................................................................... 36 7. APPENDICES ............................................................................................................................. 39 Yass Valley Wind Farm Independent Peer Review and Consultation – Final Report V2.3 Conducted by The Airport Group – 15 September 2014 3 1. EXECUTIVE SUMMARY The Airport Group (TAG) has been engaged to undertake an Independent Peer Review on the quality of the Yass Valley Wind Farm Environmental Assessment (YVWFEA) (EPURON November 2009) and the draft Response to Submissions/Preferred Project Report (RtS) (May 2014) with particular attention to the documentation provided by the NSW Department of Planning and Environment (the Department) in relation to the Director-General’s requirements, guidelines regarding draft NSW planning guidelines wind farms and industry standards and legislation. TAG was also engaged to perform a consultation, on aviation matters only, with airport/airstrip owners within the vicinity of the wind farm. This consultation has been completed and documented within this report. As per the Department’s brief, TAG has also provided recommendations and on the Peer Review and Consultation process and information contained within the reviewed documents. TAG can confirm that there is no conflict of interest with TAG performing these services for the Department. The peer review involves an impartial and independent assessment and review of the document in its entirety by independent, qualified experts. For the purposes of this review, independent means independent from stakeholders in the Yass Valley Wind Farm including those from the Department, Epuron (the proponent) and Ambidji. The peer review performed by TAG has included and documented the outcomes of the review on the following: The Proponent’s Aviation Impact Assessment; Suitability of how stakeholders and community issues were addressed in the YVWFEA; Suitability of the proposed mitigation, management and/or any protection measures; Changes required for acceptability of the project regarding aerial agricultural spraying; and Guidance (broad) with respect to the management of risks to aviation safety resulting from wind farms e.g. spraying and turbulence. Although TAG has completed the Independent Peer Review and the additional Consultation Process, there are a number of areas which will either require additional assessment, consultation or clarification including: Discrepancies identified in the methodology or assessment rationale used to perform the previous reviews; and The current 2009 legislative guidelines which TAG believes do not provide appropriate guidance appropriate to wind farm assessments. This makes the assessments of wind farms in the real world extremely difficult and requires further discussion. In summary, the following findings have been documented in detail later in this report: Whilst the Aeronautical Impact Assessment, prepared by Ambidji on 25 November 2010, included all the recommended assessments and satisfies departmental and legislation guidelines, information that has come to light after the preparation of the Ambidji report should now be included in the assessment. TAG does not agree with all the methodologies used and how the subsequent value of these results were attained; TAG found the consultation process and results by Ambidji was not accurate enough including missing information supplied to the owners of airstrips, non-effective communication methods used with the owners of air strips and not all air strip owners were consulted; Legislative guidelines require some updating; and A total of twelve landowners/stakeholders were spoken to directly either in person or via telephone. Owners of airstrips, are not satisfied and are still objecting to the development with Yass Valley Wind Farm Independent Peer Review and Consultation – Final Report V2.3 Conducted by The Airport Group – 15 September 2014 4 the only resolution of either purchasing their land, assurances that agricultural aviation activities will not be impacted, compensation, recommencement of the application including reviewing all information or not permitting the development to go ahead. Minutes of the discussions were taken and attached in the Appendix. 2. BACKGROUND The Department has requested this Independent Peer Review be undertaken by TAG. As stated in the Executive Summary, there is no conflict of interest with TAG conducting this independent peer review as TAG has had no prior contact with the Department, the proponent or Ambidji in regard to the proposed YVWFEA. TAG remains completely impartial to the outcome of the Peer Review and the Consultation Process undertaken to the development proposed. The National Airports Safeguarding Advisory Group (NASAG) is comprised of high level Commonwealth, State and Territory officials to develop a national land use planning regime that applies to airports. NASAG has created guidelines about managing the risk to aviation safety of wind turbine installations. These guidelines were last amended in July 2012 and remain current. Airservices Australia (AsA) is the Air Navigation Service Provider (ANSP) for Australia. Inevitably AsA will be required to undertake an assessment of any proposed wind farm.