FINAL REPORT

STOCKYARD HILL WIND FARM

AERONAUTICAL IMPACT ASSESSMENT

AVIATION IMPACT STATEMENT

QUALITATIVE RISK ASSESSMENT

AND

OBSTACLE LIGHTING REVIEW

180M TURBINES J0462

Copy No.: v1.1

Report to:

Origin Energy

28 April 2016

” The Ambidji Group Pty Ltd A.C.N. 053 868 778

Melbourne, Australia

© The Ambidji Group Pty Ltd, 2016

All Rights Reserved.

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.

STOCKYARD HILL WIND FARM PTY LTD STOCKYARD HILL WIND FARM - AIA AIS QRA AND OLR – 180M TURBINES

THE AMBIDJI GROUP

DOCUMENT RELEASE APPROVAL

Approved for Final Release:

Name: Ian Jennings

Title: Principal Consultant

Date: 28 April 2016

Distribution: Cara Layton, Approvals Advisor; Stockyard Hill Wind Farm; at Stockyard Hill Wind Farm Pty Ltd.

DOCUMENT CONTROL

REV DESCRIPTION DATE Prepared QA NO

V0.1 Draft for 180m turbines 17 Nov 2015 IJ

V0.2 Editorial 23 Nov 2015 IJ

V0.3 Editorial 4 Dec 2015 IJ

V0.4 Revised for OLR data 7 Dec 2015 IJ

V0.5 New location and layout diagrams 14 Dec 2015 IJ BWS

V0.6 Minor Amendments 15 Dec 2015 BWS

V0.7 Responses to AIS 16 Feb 2016 IJ

V0.8 Editorial Changes 22 Feb 2016 IJ BWS

V0.9 Amendment to layout diagram 18 April 2016 IJ BWS

V1.0 Final Report 18 April 2016 IJ BWS

V1.1 Final [image clarification made] 28 April 2016 IJ BWS

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TABLE OF CONTENTS

Executive Summary...... 4 1. Introduction ...... 9 1.1 Wind Farm Location ...... 9 1.2 Wind Farm Layout Drawing ...... 10 1.3 Aerodromes and Airstrips ...... 11 1.4 Aerodromes within 30nm ...... 12 1.5 Obstacles ...... 12 2. Scope ...... 13 3. Methodology ...... 14 3.1 Aeronautical Impact Assessment...... 14 3.2 Aviation Impact Statement ...... 14 3.2.1 Communication and Navigation Systems ...... 14 3.2.2 Surveillance Systems ...... 15 3.3 Qualitative Risk Assessment ...... 15 3.4 Obstacle Lighting Review ...... 16 4. Aeronautical Impact Assessment...... 17 5. Aviation Impact Statement ...... 17 5.1 Introduction ...... 17 5.2 Wind Farm Location ...... 17 5.3 Obstacles ...... 18 5.4 Drawings ...... 19 5.5 Aerodromes with 30 Nautical Miles – OLS and PANS-OPS Surfaces ...... 20 5.5.1 OLS Surfaces ...... 20 5.5.2 PANS-OPS Surfaces ...... 20 5.6 Air Routes and Lowest Safe Altitudes (LSALT)...... 28 5.7 Airspace ...... 29 5.8 Navigation Aids and Communications Facilities...... 29 5.9 Radar ...... 30 5.9.1 Applicable Documents ...... 30 5.9.2 Radar Installations ...... 30 5.9.3 CASA Part 139 Requirements ...... 30 5.9.4 Wind Turbines and Radars – Assessment using Eurocontrol Guidelines ...... 31 5.9.5 Assessment Requirements ...... 32 5.10 Summary and Conclusions ...... 32 5.11 AsA Response...... 32 5.12 Department of Defence Response...... 32 6. Qualitative Risk Assessment Review ...... 33 6.1 Introduction ...... 33 6.2 Aerodromes and Aircraft Landing Areas in the Region ...... 33 6.3 Airspace ...... 34 6.4 Impact on General Aviation Flying Training ...... 34 6.5 Impact on General, Recreational, Sport and Commercial Aircraft Activity ...... 35 6.6 Night Flying (IFR and VFR) ...... 36 6.7 Any Known Highly Trafficked Air Routes ...... 36

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6.8 Published Air Routes ...... 36 6.9 Impact on Victorian Emergency Services Aerial Operations ...... 37 6.9.1 Victorian Air Ambulance ...... 37 6.9.2 Victoria Police Air Wing ...... 38 6.9.3 State Aircraft Unit ...... 38 6.9.4 Aerial Fire Fighting ...... 38 6.9.5 Ground Based Fire Fighting ...... 39 6.10 Agricultural Aviation Activities ...... 40 6.11 Impact on Australian Defence Force (ADF) Operations ...... 40 6.12 Topographical and Weather Issues ...... 40 6.13 NASF Guidelines ...... 41 6.13.1 Notification to Authorities ...... 41 6.13.2 Risk Assessment ...... 42 6.13.3 Lighting of Wind Turbines in the Vicinity of an Aerodrome ...... 42 6.13.4 Risk Assessment Outcome ...... 43 6.14 Qualitative Risk Assessment Summary ...... 43 7. Obstacle Lighting Assessment ...... 45 7.1 NASF Guideline D - Managing Risk to Aviation Safety of Wind Turbine Installations (Wind Farms) and Wind Monitoring Towers ...... 45 7.2 Requirement for Obstacle Lighting ...... 45 8. Meteorological Monitoring Masts ...... 46 8.1.1 NASF Guideline – Marking of Meteorological Monitoring Masts ...... 46 8.1.2 Federal Aviation Administration – Marking of MET towers ...... 47 8.1.3 SHWF WEF Met Towers ...... 47 9. Reporting of Tall Structures ...... 47

Appendix A: Airservices Australia Aviation Assessments for Wind Farm Developments 19th August 2014 Appendix B Stockyard Hill Wind Farm, Site Identification, Coordinates and Elevations Appendix C South Australian Country Fire Service, Understanding Aerial Firefighting Appendix D Australian Fire and Emergency Services Authorities Council – Wind Farms and Bushfire Operations Appendix E Airservices Australia Response to Aviation Impact Statement Appendix F Department of Defence Response to Aviation Impact Statement Appendix G Glossary of Terms

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EXECUTIVE SUMMARY

BACKGROUND The Ambidji Group Pty Ltd has been engaged by Stockyard Hill Wind Farm Pty Ltd (SHWFPL) to prepare an Aviation Impact Statement (AIS), Aeronautical Impact Assessment (AIA), Qualitative Risk Assessment (QRA) and Obstacle Lighting Review (OLR) for the use of turbines with a 180m tip height above ground level at the Stockyard Hill Wind Farm (SHWF) in Western Victoria. Planning Permit No PL-SP/05/0548 (Pyrenees Planning Scheme) (the Permit) was issued by the Minister for Planning in October 2010 to enable the use and development of the SHWF Wind Energy Facility (SHWF WEF). The Permit allows for up to 157 turbines, with a tip height of 132m above ground level. The nearest Civil Aviation Safety Authority (CASA) registered or certified aerodromes are: Ararat - 26km (14nm) to the North West and Ballarat - 33km (18nm) to the East North East.

THIS REPORT This report is a new study assessing 149 turbines (including a modified layout) having a 180m above ground level (AGL) tip height. It has been prepared to support an application to amend the Permit. The highest ground level within the wind farm is 435.5m (T73) above the Australian Height Datum (AHD). The maximum turbine tip height is therefore 180 + 435.5 = 615.5m AHD. For aeronautical purposes this is 2019ft AHD.

AERONAUTICAL IMPACT ASSESSMENT The findings of the Aeronautical Impact Assessment are included in the Aviation Impact Statement.

AVIATION IMPACT STATEMENT The main purposes of the AIS are to determine any possible infringements by the proposed development on the: - ƒ Lowest Safe Altitudes for (LSALT) Air Routes in the vicinity; ƒ Obstacle Limitation Surfaces (OLS); and ƒ Procedures for Air Navigation Services – Aircraft Operations (PANS-OPS) surfaces; at any registered or certified aerodrome within 56km (30nm) of the wind farm boundary, as well as any impacts on the performance of: - ƒ Aviation Communications, Navigation Aids and Airspace Surveillance Systems (CNS).

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Findings At a maximum tip height of 615.5m (2109ft) the SHWF WEF will NOT infringe or impact upon any of the above items. This has been confirmed in writing by Airservices Australia (AsA) and the Department of Defence (see Appendices E and F).

QUALITATIVE RISK ASSESSMENT A Qualitative Risk Assessment is the analysis of risks through facilitated interviews or meetings with stakeholders1 and outside experts, as to the 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.

Findings The qualitative risk assessment of the SHWF WEF utilising a maximum tip height of 615.5m (2109ft) AHD shows that the assessed level of risk to aviation safety is LOW and is therefore not a hazard to aviation safety2. No additional mitigation of risk, particularly aviation obstacle lighting, is considered necessary. The QRA findings are summarised in the table below.

Risk Element Assessed Comment Level of Risk Aerodrome Operations LOW The nearest certified or registered aerodromes are at least 26km (14nm) distant and no infringement of prescribed airspace3 occurs. Aeroplane Landing Area (ALA) LOW It is the responsibility of the pilot in command to Operations ascertain the suitability of an ALA for the proposed aviation operation Known Highly Trafficked Routes LOW Flying schools from Ballarat use the area between Ballarat, Mt Emu, Beaufort, and Clunes for flying training. Stakeholder interviews confirmed that these flights are normally safely outside the wind farm area. Published Air Routes LOW No infringement of published LSALT Restricted Airspace LOW None identified in the vicinity. Promulgated Flying Training Areas LOW None identified in the vicinity. Instrument Flight Training LOW Instrument flight training occurs at Yarrowee radio Yarrowee (YWE) Navaid navigation aid, located 24km (13nm) distant. The SHWF does not impact on this Instrument Approach. Night Flying LOW Protected by LSALT

1 The list of local stakeholder interviews is held by Ambidji and is available on request. 2 National Airports Safeguarding Framework Guideline D paragraph 34, dated 15 July 2012 3 Prescribed airspace refers to the airspace above the Obstacle Limitation Surface, Lowest Safe Altitude and Procedures for Air Navigation-Operations surfaces. Obstacle penetration of prescribed airspace is normally not permitted.

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Risk Element Assessed Comment Level of Risk Recreational/Commercial Flying LOW Sufficiently distant from Registered or Certified aerodromes to not impact on operations. General Aviation Pilot Training LOW Flying schools from Ballarat use the area between Ballarat, Mt Emu, Beaufort, and Clunes for flying training. Stakeholder interviews confirmed that these flights are normally safely outside the wind farm area. Aerial Agricultural Operations LOW Pilots conduct risk assessments of all operations. Air Ambulance Operations LOW Pilots conduct risk assessments of all operations. Police Aviation Operations LOW Pilots conduct risk assessments of all operations. Fire Fighting Operations LOW Aerial access restricted but ground access improved. Weather and Visibility Issues LOW There are major highways that provide sufficient visual reference, even during periods of marginal VMC4, to keep pilots clear of the wind farm and therefore mitigate the risk to LOW. Summary of Qualitative Risk Assessment

OBSTACLE LIGHTING REVIEW FINDINGS An Obstacle Lighting Review (OLR) assesses current international and national documentation applicable to obstacle marking and lighting requirements in regard to any requirement for aviation obstacle lighting of the proposed wind farm. The results of the QRA show that the SHWF WEF has a LOW risk to aviation and will not be a hazard to aviation safety. No additional mitigation of risk, including aviation obstacle lighting, is considered necessary. In accordance with the National Aerodrome Safeguarding Framework, Guideline D paragraph 34 the risk assessment shows that the SHWF WEF meets the criteria of the second dot point; i.e. not a hazard to aircraft safety5 For illustrative purposes it is noted that: - ƒ The Instrument Approach Procedure Plates 6 for Ballarat RNAV-Z RWY 18 and NDB RWY 36, dated 6 MAR 2014, have an editorial note that the nearby wind farm obstacle lighting has been decommissioned. ƒ There is an existing unlit wind farm closer to Ararat aerodrome marked on the aeronautical charts7. Civil Aviation Safety Regulations Part 139 – Aerodromes is considered to be applicable only within the confines of the Obstacle Limitation Surfaces or Procedures for Air Navigation Services – Aircraft Operations surfaces of an aerodrome.

4 Visual Meteorological Conditions; a set of conditions mandated for the continuation of non-instrument flight. 5 National Airports Safeguarding Framework Guideline D paragraph 34, dated 15 July 2012 6 Aeronautical Information Publication, Departure and Approach Procedures EAST Amendment 139, 20 August 2015 7 Challicum Hills Wind Farm is marked on the relevant aeronautical charts.

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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 supporting CASR 1998) AHD Australian Height Datum AIA Aeronautical Impact Assessment AIP Aeronautical Information Publication AIS Aviation Impact Statement ALA Aeroplane Landing Area 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 ERSA Enroute Supplement Australia ft feet GA General Aviation GNSS Global Navigation Satellite System ICAO International Civil Aviation Organisation IFR Instrument Flight Rules km kilometres LAT Latitude LONG Longitude LSALT Lowest Safe Altitude m metres MOC Minimum Obstacle Clearance MOS Manual of Standards, published by CASA MSA Minimum Sector Altitude SSR Monopulse Secondary Surveillance Radar NASAG National Airports Safeguarding Advisory Group NASF National Airports Safeguarding Framework NDB Non Directional Beacon nm Nautical Mile (= 1.852 km) NOTAM NOtice To AirMen OLR Obstacle Lighting Review OLS Obstacle Limitation Surface

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Abbreviation Meaning PANS-OPS Procedures for Air Navigation Services – Aircraft Operations PSR Primary Surveillance Radar QRA Qualitative Risk Assessment RPT Regular Public Transport RWY Runway SFC Surface SHWFPL Stockyard Hill Wind Farm Pty. Ltd. SHWF WEF Stockyard Hill Wind Farm Wind Energy Facility SSR Secondary Surveillance Radar VFR Visual Flight Rules VOR Very high frequency Omni directional Range YARA Ararat Registered Aerodrome YBLT Ballarat Registered Aerodrome YWE Yarrowee Navigation Aid

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1. INTRODUCTION

The Ambidji Group Pty Ltd has been engaged by Stockyard Hill Wind Farm Pty Ltd (SHWFPL) to prepare an Aeronautical Impact Assessment (AIA), Aviation Impact Statement (AIS), Qualitative Risk Assessment (QRA) and an Obstacle Lighting Review (OLR) for taller turbines at the Stockyard Hill Wind Farm (SHWF) in Western Victoria. Planning Permit No PL-SP/05/0548 (Pyrenees Planning Scheme) (the Permit) was issued by the Minister for Planning in October 2010 to enable the use and development of the SHWF Wind Energy Facility (WEF). The Permit allows for up to 157 turbines, with a tip height of 132 metres above ground level (AGL). Specifically, this document has been prepared to support an application to amend the Permit to allow for 149 turbines (including a modified layout), with a 180m AGL tip height. The highest ground level within the wind farm is 435.5m (T73) above the Australian Height Datum (AHD). The maximum turbine tip height is therefore 180 + 435.5 = 615.5m AHD. For aeronautical purposes this is 2019ft AHD.

1.1 Wind Farm Location

The proposed wind farm is located approximately 33km west of Ballarat and encompasses an area from approximately 5km south of Beaufort to approximately 4km north of Skipton, and is centred on Stockyard Hill in Victoria. Figure 1.1 shows the location of the proposed SHWF WEF.

Figure 1.1 – General Location of SHWF WEF8

8 From information supplied by Origin Energy

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1.2 Wind Farm Layout Drawing

A drawing of the wind turbine locations is shown in Figure 1.2 below.

Figure 1.2 Layout of the SHWF WEF showing Wind Turbine Locations9

9 Layout chart supplied by Origin Energy

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1.3 Aerodromes and Airstrips

Aerodromes fall into four categories: ƒ Military or Joint User (combined military and civilian); ƒ Certified; ƒ Registered; and ƒ 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 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 Publication10 (AIP) and are subject to a NOTAM11 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. 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, AsA 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. Military, Joint, Certified and Registered aerodromes usually have OLS and PANS-OPS surfaces prescribed to protect the airspace associated with published instrument approach and landing procedures. An ALA cannot have a published instrument approach and landing procedure so cannot have associated prescribed airspace

10 AIP; a mandatory worldwide distribution system for the promulgation of aviation rules, procedures and information 11 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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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).

1.4 Aerodromes within 30nm

The following registered or certified aerodromes are within 30nm (56km) of the nearest wind turbine within the SHWF WEF. The distances are measured to the Aerodrome Reference Point (ARP) at each aerodrome.

Aerodrome Distance from SHWF Direction from SHWF Ararat (registered) YARA 14nm (26km) NW Ballarat (registered) YBLT 18nm (33km) ENE Table 1.1 Registered or Certified Aerodromes with 30nm of SHWF WEF

1.5 Obstacles

The highest ground level within the wind farm is 435.5m (T73) AHD. The maximum turbine tip height is therefore 435.5 + 180 = 615.5m AHD. For aeronautical purposes this is 2019ft AHD. This is the altitude above which the minimum requisite VFR or Instrument Flight Rules (IFR) obstacle clearances must be referenced to ensure safety.

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2. SCOPE

This study has been prepared to support an application to amend the Permit to allow for 149 turbines (including a modified layout), with a 180m AGL tip height, and included the following tasks: ƒ Prepare an AIA, particularly in respect to the OLS and PANS-OPS surfaces within the vicinity of the proposed SHWF WEF. ƒ Prepare an AIS, in accordance with the requirements of AsA letter “Airservices Aviation Assessments for Wind Farm Development” dated 19 August 2014; ƒ Prepare a QRA in regard to the need for obstacle lighting which included: ƒ The identification and assessment of potential aviation risk elements through: x Reference to CASA publications; x Reference to the Australian Aeronautical Information Publication (AIP); x Reference to the National Airports Safeguarding Framework (NASF) guidelines; x Consultations with key relevant stakeholders; ƒ Assessment of the perceived impacts of the turbines on the operation of aerodromes and airstrips in the immediate vicinity of the wind farm; ƒ Assessment of the perceived impacts of the turbines on aviation activity including: x General Aviation training; x Recreational/Commercial flying activity; x Air Ambulance Operations; x Police Aviation Operations; x Aerial Fire Fighting Operations; x Aerial Agricultural Operations; x Known highly trafficked VFR routes; x Night flying for light aircraft; ƒ Assessment of any implications for the above from topographical, weather and visibility issues; ƒ Assessment of other issues as identified through consultations and the assessment process; ƒ Conclusions on the degree of aviation risk posed by the above described issues with commensurate recommendations on any mitigating actions. ƒ Prepare an Obstacle Lighting Review (OLR) to assess the need, against the outcomes of the QRA, for obstacle lighting of the wind farm. The OLR considers and comments on current international practice for lighting wind farms, CASA’s position and the applicability of their regulations or advice, NASF guidelines for wind farms and the status of trends in lighting decisions with other planned and operational wind farms in Australia.

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3. METHODOLOGY

3.1 Aeronautical Impact Assessment

The Aeronautical Impact Assessment considers the existing facilities at nearby CASA registered or certified aerodromes within 56km (30nm) of the boundary of the proposed SHWF WEF. This AIA was undertaken as follows: ƒ OLS infringements were accurately determined based on the siting information and airport layouts as detailed in the Australian AIP and publicly available Airport Master Plan documents; ƒ The relevant publicly available instrument approach and departure procedures and associated PANS-OPS surfaces were examined in detail to determine whether the development would impose any restriction on those procedures. Any restriction on the instrument procedures would have to be examined by AsA to assess the impact to these procedures and associated safety regulation standards; ƒ Existing flight paths along with likely future flight paths were examined in relation to the proposed development to determine if there would be any impact on future procedures; ƒ Flying training areas associated with civil and military flying training were assessed in relation to the location of the proposed development to determine if there would be any impact upon those operations; and ƒ A concise summary was made of the findings and any impediments to aviation operations.

3.2 Aviation Impact Statement

The detailed Aviation Impact Statement was carried out in accordance with AsA requirements to provide a report that reviews and assesses the items set out in the AIA and any likely impact on Communication, Navigation and Surveillance systems (CNS) used for the provision of Air Traffic Control.

3.2.1 Communication and Navigation Systems

The following items were reviewed and assessed: ƒ Published aeronautical information of the siting of radio communication facilities in the vicinity of the wind farm and its likely impact on the safety of aviation; and ƒ Published aeronautical information of the siting of radio navigation aids in the vicinity of the wind farm and its likely impact on the safety of aviation.

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3.2.2 Surveillance Systems

The following items were reviewed and assessed: ƒ Information on the siting of aviation surveillance systems (radar) and the likely impact of the wind farm on the surveillance information available to Air Traffic Control systems; ƒ The probability of detection by the surveillance system; and ƒ Radar coverage implications. Conduct an analysis of the impact of the wind farm on nearby surveillance systems in accordance with the EUROCONTROL Guidelines on how to Assess the Potential Impact of Wind Farms on Surveillance Sensors.12 This assessment involves an iterative five step process: 1. Initial Line of Sight Analysis (ILoS). Where the distance of the objects of interest are beyond the instrumented range of the radar no further analysis is undertaken; 2. Simple Line of Sight Analysis (SLoS). Where the distance of the objects of interest are within the instrumented range of the radar a computation is required to ascertain if the Line of Sight of the radar is infringed; 3. Complex Line of Sight Analysis (CLoS). If the Simple Line of Sight is infringed a more complex analysis is required whereby intervening terrain and objects are taken into account. If the objects still infringe the radar then a more complex analysis is required; 4. Radar Line of Sight (RLoS). This analysis is undertaken where the CLoS is within the instrumented range of the radar. For this analysis specific characteristics of the radar are taken into account to ascertain likely detection of the objects by the radar; and 5. Radar Clutter Detection Reduction Methods (RCDRM). If the RLoS determines a finite probability of detection then an assessment of the possible clutter produced by the objects of interest, if operationally significant, may be justified. The results of this process are then used to determine if the proposed SHWF WEF poses an acceptable or unacceptable risk to aviation safety through its impact on air traffic control surveillance systems.

3.3 Qualitative Risk Assessment

A Qualitative Risk Assessment (QRA) 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 QRA considers the hazard posed by the proposed SHWF WEF to aviation activity in the area. The methodology for the QRA was as follows:

12 URL http://www.eurocontrol.int/surveillance/public/standard_page/sur_WTTF.html

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ƒ The 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; ƒ Current topographical maps were studied to assess the local terrain and identify any local airstrips and any other relevant features; ƒ 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; ƒ Published studies for the proposed wind farm and similar wind farms in the surrounding area were reviewed; ƒ Consideration of the NASF Guidelines, particularly Guideline D, Managing the Risk to Aviation of Wind Turbine Installations (Wind Farms)/ Wind Monitoring Towers; ƒ 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; x General Aviation training; x Recreational and sport aviation activities; x Approved low flying activities (including aerial agricultural applications) x Any known highly trafficked VFR routes; and x Emergency Services (air ambulance, police and fire service); ƒ In addition, further consideration was given to the consequences (for the above elements) of the potential influence of topography and poor weather.

3.4 Obstacle Lighting Review

An Obstacle Lighting Review (OLR) was undertaken as follows: ƒ A review of international and national aviation documentation applicable to aeronautical hazard assessments and obstacle marking and lighting requirements, with particular consideration of wind turbines and wind farms; ƒ Reference to the current CASA position for marking and lighting of obstacles for wind farms; ƒ A review of the current NASF Guideline D for wind farms; and ƒ The implications, from the above, in regard to any requirement for aviation obstacle lighting of the proposed wind farm.

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4. AERONAUTICAL IMPACT ASSESSMENT

The AIS reports on the items covered in the AIA. To reduce duplication the results of the AIA are reported in the AIS.

5. AVIATION IMPACT STATEMENT

The AIS contains the analysis of any impact the SHWF WEF may have on the OLS and PANS-OPS surfaces associated with Instrument Departure and Approach Procedures for the aerodromes at Ararat and Ballarat and the radio navigation aid at Yarrowee.

5.1 Introduction

On 19 August 2014, AsA reissued a letter detailing the requirements for the provision of an AIS for Wind Farm developments13. The AsA letter requires that the AIS be submitted to them for evaluation and consideration. A copy of this letter is shown at Appendix A. The main purposes of this AIS are to determine any possible infringements by the proposed development on the OLS and the PANS-OPS surfaces at any registered or certified aerodrome within 30nm of the wind farm boundary, and LSALT for Air Routes in the vicinity and on the performance of Navigation Aids and Airspace Surveillance Systems. Details of Aerodromes, OLS, PANS-OPS procedures, LSALT, and CNS facilities were obtained from the AIP, AsA sources and CASA publications.

5.2 Wind Farm Location

The proposed SHWF WEF is located approximately 33km west of Ballarat and encompasses an area from approximately 5km south of Beaufort to approximately 4km north of Skipton, and is centred on Stockyard Hill in Victoria. The general location of the SHWF WEF is shown in Figure 5.1.

13 The original letter was issued 5 March 2012

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Fig 5.1: General Location of the Proposed SHWF WEF

5.3 Obstacles

A list of the wind turbine locations and elevations AHD/AMSL is shown in Appendix B. Coordinates are in WGS 84, accurate to 0.1 second of arc, and elevations Above Mean Sea Level (AMSL) are accurate to 0.3 metres. The highest turbine tip is T73 at 615.5 m (2019ft) AHD.

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5.4 Drawings

A drawing of the wind turbine locations is shown in Figure 5.2 below.

Figure 5.2 Layout of the SHWF WEF showing Wind Turbine Locations

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5.5 Aerodromes with 30 Nautical Miles – OLS and PANS-OPS Surfaces

There are two registered or certified aerodromes within 30nm of the SHWF WEF, located at Ballarat (YBLT), 18nm (33km) to the east, and Ararat (YARA) 14nm (26km) to the North West.

5.5.1 OLS Surfaces

OLS surfaces extend to a distance of 15km from the Aerodrome Reference Point (ARP), and as YBLT and YARA are respectively in excess of this distance from the nearest wind farm turbine, the OLS surfaces are not infringed.

5.5.2 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 11° east. Aircraft performance category (CAT) is published in the CASA MOS Part 173. ARARAT There are no PANS-OPS procedures published for Ararat Aerodrome. BALLARAT There are 3 PANS-OPS approach procedures published for Ballarat Aerodrome, as well as a common Minimum Sector Altitude (MSA). All procedures are limited to CAT A and B aircraft. These procedures have been examined to determine if there is impact by the SHWF WEF. MSA The MSA is within 25nm of YBLT, and is thus over the SHWF WEF. The lowest MSA is 3100ft. The highest turbine tip (T73) is 2019ft, and when the MOC of 1000ft is applied the result is 3019ft, which is below the MSA. The MSA is not impacted by the SHWF WEF. RWY 36 NDB APPROACH This procedure is for the Ballarat Non Directional Beacon (NDB) approach to runway 36 (RWY 36). This approach procedure is shown in Figure 5.3

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Figure 5.3 YBLT RWY 36 NDB Approach Holding Holding at the NDB is a 1minute right hand pattern, inbound 184°M, minimum holding altitude 3700ft. The tolerances for this holding pattern are unlikely to extend to the SHWF WEF and were not plotted.

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However even if the tolerances extended to the SHWF WEF area, there will not be a penetration of the 3700ft minimum holding altitude, as the highest wind turbine tip is T73 at 2019ft, and when the MOC of 1000ft is applied the result is 3019ft, which is below the minimum holding altitude. Base Turn From the NDB the outbound track of the base turn reversal procedure is 184°M for 2.5 minutes, then a left turn to track 349°M to the NDB. Descent is from 3700ft to 2800ft until inbound to the NDB then descent to 2110ft. The tolerances of the base turn area have been constructed in accordance with ICAO Doc 8168 PANS-OPS Part 1 Chapter 3 Appendices B-1 and C, construction of the simplified area, and are shown in Figure 5.4. The green lines show the tolerance area nearest to the WF, and the WF boundary is 6.8 nm from this area. The RWY 36 NDB approach is not impacted by the SHWF WEF.

Figure 5.4 YBLT RWY 36 NDB Approach Base Turn Tolerances

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RWY 36 RNAV-Z (GNSS) APPROACH This approach procedure is shown in Figure 5.5

Figure 5.5 YBLT RWY 36 RNAV-Z (GNSS) Approach

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Holding Holding is at the BLTSB waypoint and is a 1minute left hand pattern, inbound 357°M, minimum holding altitude 4000ft. The tolerances for this holding pattern are unlikely to extend to the SHWF WEF and were not plotted. However even if the tolerances extended to the SHWF WEF area, there will not be a penetration of the 4000ft minimum holding altitude, as the highest wind turbine tip is T73 at 2019ft, and when the MOC of 1000ft is applied the result is 3019ft, which is below the minimum holding altitude. Initial Approach Fix (IAF) to Initial Fix (IF) The significant part of the RNAV Approach Procedure is the Minimum Segment Altitude of 2900ft from the IAF at waypoint BLTSC to the IF at BLTSI. The tolerances for this part of the procedure have been constructed in accordance with ICAO Doc 8168 PANS-OPS Part III Section1 Chapter 2 and are shown in Figure 5.6. The green lines show the tolerance area nearest to the SHWF WEF, and the SHWF WEF boundary is 9nm from this area. The RWY 36 RNAV-Z (GNSS) approach is not impacted by the SHWF WEF.

Figure 5.6 YBLT RWY 36 RNAV-Z (GNSS) Approach from BTLSC to BTLSI

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RWY 18 RNAV-Z (GNSS) APPROACH This procedure is shown in Figure 5.7.

Figure 5.7 RWY 18 RNAV-Z (GNSS) Approach

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Holding Holding is at the BLTNE waypoint and is a 1 minute left hand pattern, inbound 163°M, minimum holding altitude 4700ft. The tolerances for this holding pattern were not plotted as it is 22nm from the nearest SHWF WEF boundary and the lowest holding altitude is well above the highest wind turbine tip of 2019ft plus MOC of 1000ft resulting in 3019ft. Missed Approach Procedure The significant part of this RNAV Approach is the Missed Approach Procedure track of 178°M from waypoint BLTNH. Tolerances for this part of the procedure have been constructed in accordance with ICAO Doc 8168 PANS-OPS Part III Section1 Chapter 2 and are shown in Figure 5.8. The green lines show the tolerance area nearest to the SHWF WEF, and the SHWF WEF boundary is 12.6nm from this area. The RWY 18 RNAV (GNSS) approach is not impacted by the SHWF WEF.

Figure 5.8 RWY 18 RNAV-Z (GNSS) Approach

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YARROWEE (YWE) NDB APPROACH This approach is shown in Figure 5.9

Figure 5.9 Yarrowee NDB Approach

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There is no aerodrome at Yarrowee, and this approach is provided for training purposes and must be flown in VMC by day only. Pilots are responsible to see and avoid all obstacles. Tolerances for this procedure have not been constructed, however the MSA and holding for the approach is at 4000ft, 981ft above the highest turbine tip of 2019ft plus MOC of 1000ft. The approach and missed approach tracks are aligned from NE to SW and are at least 13nm from the SHWF WEF boundaries and circling is limited to within 3nm of the NDB. The Yarrowee NDB approach is not impacted by the SHWF WEF.

5.6 Air Routes and Lowest Safe Altitudes (LSALT)

A number of published air routes are in the vicinity and are shown in Figure 5.10 below.

Figure 5.10 Air routes in the vicinity of the SHWF WEF (approximate boundaries)

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The GRID LSALT and significant air routes and LSALTs are shown in Table 5.1.

Route Section LSALT GRID 4800ft W306 YWE-BURRA 4800ft W291 YWE-HSM 4800ft W245 YWE-HML 4100ft W191 YWE-MTG 4100ft W657 YWE-BLT 3500ft W418 HML-AV VOR 4100ft Table 5.1 LSALTs The highest turbine tip is 2019ft AHD, and when the MOC of 1000ft is applied the result is 3019ft AHD. As the lowest LSALT is 3500ft on W657, none of the LSALTs are impacted by the SHWF WEF.

5.7 Airspace

The SHWF WEF is situated in non – controlled Class G airspace, beneath controlled Class E airspace above 8500ft. The SHWF WEF will not create any restriction to the use of Class G airspace by commercial, general and recreational flying, including flying training activities.

5.8 Navigation Aids and Communications Facilities

CASR Part 139 Manual of Standards – Aerodromes, Chapter 11, sets out the general requirements for navigation aid sites and air traffic control (ATC) facilities, including the clearance planes for planned and existing facilities. The nearest Navigation Aids to the SHWF WEF and distance from the SHWF WEF boundary are as follows: ƒ Yarrowee NDB, 29km ƒ Ballarat NDB, 32km The restricted area applicable to an NDB is 150m, (Part 139 MOS, paragraph 11.1.13.1 refers). As the SHWF WEF is well beyond the restricted areas for both NDBs, it will not impact on the performance of any Navigation Aids. Remote communication facilities are located on Mt William (1150m AHD), 58km to the NW of the SHWF WEF. At this distance and height, the SHWF WEF will not impact on the performance of the communication facilities.

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5.9 Radar

5.9.1 Applicable Documents

There are two documents, considered applicable, concerning the regulations and recommendations that apply to radar installations and the proposed SHWF WEF. These are: ƒ CASA Part 139 Manual of Standards (MOS) Aerodromes, and ƒ The Eurocontrol Document “Guidelines on How to Assess the Potential Impact of Wind Turbines on Surveillance Sensors”, Edition date: May 2010; Reference nr: EUROCONTROL-GUID-0130 The Eurocontrol document is referred to (by link) in the AsA letter dated 19 August 2014, which is shown in Appendix A.

5.9.2 Radar Installations

The nearest radar systems to the SHWF WEF operated by AsA are: ƒ an enroute Secondary Surveillance Radar (SSR) located at Mt Macedon, approximately 102km to the north east; and ƒ a Terminal Airspace Radar system (PSR and SSR) for Melbourne Airport, approximately 125km to the east.

5.9.3 CASA Part 139 Requirements

CASA Part 139 MOS – Aerodromes stipulates the siting criteria to ensure unrestricted performance of navigation aids, radar sensors and other aviation facilities located on and in the vicinity of aerodromes. Buildings, structures or terrain that is higher than the radar coverage, or radar clearance plane, can hide aircraft behind the particular object, affectively placing a radar shadow in a particular area thus reducing the ability of ATC to effectively control aircraft within the area of the shadow. Para 11.1.14.4 (b) of the CASA MOS Part 139 states: No metallic or other electrical reflective surfaces anywhere which subtend an angle of more than 0.5 degrees when viewed from the radar, e.g. fences, power lines, tanks as well as many buildings. The distances and the heights of the SHWF WEF turbines relative to the Mt Macedon and Melbourne Airport radars ensure that the requirement of MOS Part 139 Para 11.1.14.4 (b) is met.

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5.9.4 Wind Turbines and Radars – Assessment using Eurocontrol Guidelines

The following is from the Eurocontrol Document “Guidelines on How to Assess the Potential Impact of Wind Turbines on Surveillance Sensors” Edition date: May 2010 Reference nr: EUROCONTROL-GUID-0130. The requirements are applicable to current wind turbine design, e.g. 3-blades, 30- 200m height, horizontal rotation axis. The Eurocontrol document is referred to by AsA in its letter dated 19 August 2014 (see Appendix A) for the assessment of the impact on AsA Radars. Primary Surveillance Radar (PSR) ZONE 1: 0 - 500m Requirement: Safeguarding (not permitted) ZONE 2: 500m - 15km and in radar line of sight Requirement: Detailed assessment ZONE 3: Further than 15km but within maximum instrumented range and in radar line of sight Requirement: Simple assessment ZONE 4: Anywhere within maximum instrumented range but not in radar line of sight or outside the maximum instrumented range. Requirement: No assessment Secondary Surveillance Radar (SSR) (Classical, Monopulse and Mode S) ZONE 1: 0 - 500m Requirement: Safeguarding (not permitted) ZONE 2: 500m - 16km but within maximum instrumented range and in radar line of sight Requirement: Detailed assessment ZONE 4 Further than 16km or not in radar line of sight Requirement: No assessment It is to be noted that in the case of SSR there is no simple assessment zone 3. When outside the radar line of sight of an SSR the impact of the wind turbine is considered to be tolerable. When further than 16km from an SSR the impact of a wind turbine (3-blades, 30-200 m height, and horizontal rotation axis) is considered to be tolerable.

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5.9.5 Assessment Requirements

Both the Mt Macedon and Melbourne Airport radars are located well beyond the distance which would require any further assessment and the SHWF WEF will not impact on the performance of any radar systems.

5.10 Summary and Conclusions

The AIS concluded that the SHWF WEF development will NOT impact upon the following: ƒ The OLS and PANS-OPS surfaces of any registered or certified aerodrome; ƒ The LSALT for air routes in the vicinity; ƒ The performance of Navigation Aids and Communication Facilities; and ƒ The performance of any radars and their site monitors

5.11 AsA Response

AsA responded to the AIS by e-mail dated 15 February 2016 (see Appendix E). AsA advise that the SHWF WEF will not impact, at a maximum height of 615.5m (2020ft) AHD, on any sector or circling altitude, nor any instrument approach or departure procedure at Ballarat aerodrome or Yarrowee NDB. They further advise that the SHWF WEF will not impact on any AsA CNS facilities.

5.12 Department of Defence Response

The Department of Defence responded to the AIS by letter dated 16 February 2016 (see Appendix F). Defence advise that they have no objection to the proposed development at a maximum height of 615.5m (2020ft) AHD. Defence request that should LED obstruction lighting be required for these turbines, the frequency range of the LED light must fall with the range of wavelengths 655 to 930 nanometres, to ensure visibility to aircrew using night vision devices.

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6. QUALITATIVE RISK ASSESSMENT REVIEW

6.1 Introduction

This QRA considers the risk posed to known aviation in the area by the proposed wind farm. 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 military, certified or registered aerodrome within 56km (30nm) of a wind farm is considered. The list of stakeholders interviewed for this QRA is held by Ambidji and is available from the author on request.

6.2 Aerodromes and Aircraft Landing Areas in the Region

The approximate distance and direction to aerodromes and ALA identified within 30nm (56km) of the SHWF WEF are tabulated in Table 6.1.

Aerodrome/ALA Distance from SHWF Direction from SHWF Boundary Ararat (registered) 14nm (26km) NW Ballarat (registered) 18nm (33km) ENE Beaufort ALA 1.66nm (2.16km) E Derrinallum ALA 18.4nm (34km) SSW Lake Bolac ALA 18nm (33km) WSW Kurweeton ALA 18.4nm (34km) WSW Raglan ALA 4.8nm (9km) NNE Trawalla ALA 3.2nm (6km) NNE Westmere ALA 16.8nm (31km) WSW Table 6.1 Identified Aerodromes and ALAs within the vicinity of SHWF WEF The aviation activities identified at each of the aerodromes and ALAs are tabulated in Table 6.2 below.

Aerodrome/ALA Nature of Aviation Activity

Ararat (registered) GA, Gliding Ballarat (registered) GA Flying Training, Gliding, commercial Beaufort ALA Private Derrinallum ALA Aerial Agricultural Aviation Kurweeton ALA Not known Lake Bolac ALA Private Raglan ALA Ultra-light Aircraft Trawalla ALA Ultra-light Aircraft Westmere ALA Not known Table 6.2 Aviation activities identified at each aerodrome and ALA

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The SHWF WEF does not penetrate the OLS or PANS-OPS surfaces associated with the registered aerodromes at Ararat and Ballarat (see section 5). The use of an ALA is governed by CAR 92 which places the responsibility on the pilot in command to ensure “… … that having regard to all the circumstances of the proposed landing or take-off (including the prevailing weather conditions), the aircraft can land at, or take-off from, the place in safety.”14 The CAAP 92-1(1) Guidelines for Aeroplane Landings Areas, sets out factors that may be used to determine the suitability of a place for the landing and taking-off of aeroplanes.15 The closest ALA to the SHWF WEF is the Beaufort ALA. Previous reports16 and correspondence indicate that this private airstrip is used on an ad-hoc basis for private light aircraft, aerial agricultural operations and by Ballarat Aero club training flights as a practice out landing airstrip. There is a substantial plantation of trees on higher ground to the west that crosses the extended runway centreline approximately midway between the end of RWY 29 and the closest wind turbine (T27). This plantation is an obstacle to operations that requires a departing aircraft to be able to either climb above it or execute a turn away from it. By executing a right turn a departing aircraft would avoid the plantation as well as the turbines of the SHWF WEF.

6.3 Airspace

The SHWF WEF is situated in non – controlled Class G airspace, beneath controlled Class E airspace above 8500ft. The SHWF WEF will not create any restriction to the use of Class G airspace by commercial, general and recreational flying, including flying training activities. The Yarrowee (YWE) radio navigation aid, located 13nm (24km) SE of SHWF WEF, is used extensively for IFR training. There is no aerodrome at YWE however there is a published Instrument Approach Procedure associated with the navigation aid. The MSA and holding altitude for the approach is 4000ft which is well above the 3019ft safety altitude of the highest turbine tip. The training approach is to be used in day VMC only and any circling must be within 3nm of the navigation aid. The pilot in command is responsible for maintaining visual separation with all obstacles, including the SHWF WEF.

6.4 Impact on General Aviation Flying Training

There are no published flying training areas within the vicinity of the SHWF WEF, although there are Flying Schools located at Ballarat Aerodrome.

14 Civil Aviation Regulation (1988) CAR 92 (1) 15 Civil Aviation Advisory Publication CAAP 92-1(1), July 1992 16 Aviation Assessment Proposed Stockyard Hill Wind Farm; Hart Aviation, 30 December 2011; COR-SHWF-Hawker 20101122 Letter to King re Beaufort Airfield; COR-SHWF-Hawker 20110307 Record of contact re aviation safety; COR-SHWF-Hawker 20120425 Fax airfield concerns; and COR-SHWF-Hawker 20120507 Fax re Correspondence to DCPD requesting revoking permit

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All ab-initio flying training is conducted in accordance with the VFR as defined in Division 3 of the Civil Aviation Regulations (CAR) (1988). 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. Flight conducted in accordance with the IFR is subject to more stringent obstacle and terrain clearance rules and must be above the published or calculated LSALT. The Flying Schools at Ballarat use an area bounded by Ballarat, Lake Burrumbeet, Mt Emu, Beaufort and Clunes for their general training flights which are usually accompanied by an Instructor. One school uses the Beaufort ALA (YBFT) for out landing practice and another uses it for identification of suitable forced landing areas. This general area is east of the SHWF WEF, consequently such training flights would normally be outside its boundaries. It is also noted that there are existing wind farms within the general area between Ballarat and Ararat. IFR flying training at the YWE radio navigation aid will not be impacted by the SHWF WEF as noted in the AIS at 5.5 above.

6.5 Impact on General, Recreational, Sport and Commercial Aircraft Activity

Recreational general aviation is normally conducted in accordance with the VFR. VFR operations must be flown in accordance with Civil Aviation Regulation (CAR 1988) 157 which requires 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. Recreational or Sport aviation flown in Recreational Aviation Australia (RAA-Aus) registered micro-light or ultra-light aircraft are limited to VFR flight, by day, in Class G airspace. Certain ultra-light aircraft, whilst exempt from CAR 157, must be flown not lower than 500ft/152m above the highest terrain, during daylight only and in accordance with the VFR which requires the pilot to maintain separation from obstacles as well as other aircraft. Discussion with Gliding Federation Australia Safety Managers indicated that wind farms have little impact on gliding operations, even when the gliding fields are located near wind farms. Similarly Hang Gliding and Parachute peak bodies at the State level have indicated that wind farms have little impact on their flying activities. Commercial General Aviation fixed wing flying is mostly charter operations conducted under Instrument Flight Rules (IFR) where LSALT’s apply. The Grid LSALT is 4800ft. Given the tip height of 615.5m/2019ft for the highest wind turbines for the proposed SHWF WEF, the Grid LSALT and the requirement for a pilot undertaking VFR flight to maintain prescribed minimum vertical and horizontal clearances from obstacles, there will be minimal impact on both VFR and IFR flight in the vicinity.

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6.6 Night Flying (IFR and VFR)

Aircraft flying at night under either VFR or IFR are protected by published or calculated LSALT and descent below them is restricted to within 10km/5.5nm of the aerodrome environs and in VMC. As noted in Section 6.2 the SHWF WEF is sufficiently distant from YBLT and YARA registered aerodromes to be clear of prescribed airspace and is sufficiently below the Grid and published LSALT’s for air routes in the vicinity to have minimal impact on night flying.

6.7 Any Known Highly Trafficked Air Routes

The lower limit of Class E airspace over the SHWF WEF is 8500ft. The maximum turbine tip height within the wind farm is 2019ft. To comply with the VFR obstacle clearance requirements of CAR 157 an aircraft needs to maintain a minimum altitude of 2519ft (2019 + 500) over the SHWF WEF. This altitude is well below Class E controlled airspace providing more than adequate Class G airspace for VFR operation of General Aviation, Gliding, Sport and Recreational aviation activity. The SHWF WEF will have minimal impact on any highly trafficked routes from Ballarat to Ararat/Hamilton and beyond or IFR flying training at Yarrowee given that it: - ƒ Will be marked on aeronautical charts so that aircraft pilots know of its existence and extent; ƒ Provides adequate clearance to operate in class G airspace and remain below Controlled Airspace (CTA) class E; ƒ Is sufficiently distant from the YWE navaid; and ƒ Is sufficiently distant from YARA and YBLT aerodromes. The Flying Schools at Ballarat (see Section 6.4) use an area bounded by Ballarat, Lake Burrumbeet, Mt Emu, Beaufort and Clunes for their general training flights which are usually accompanied by an Instructor. One school uses the Beaufort ALA (YBFT) for out landing practice and another uses it for identification of suitable forced landing areas. This general area is to the east of the SHWF WEF boundary and does not entail flight over the SHWF WEF; consequently the risk to such training flights posed by the SHWF WEF is low.

6.8 Published Air Routes

A number of published air routes pass over, or are in the vicinity of, the SHWF WEF as shown in Figure 6.1.

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Figure 6.1 Air routes in the vicinity of the SHWF WEF The GRID LSALT and significant air routes and LSALTs are shown in Table 6.3.

Route Section LSALT GRID 4800ft W306 YWE-BURRA 4800ft W291 YWE-HSM 4800ft W245 YWE-HML 4100ft W191 YWE-MTG 4100ft W657 YWE-BLT 3500ft W418 HML-AV VOR 4100ft Table 6.3 LSALTs The highest turbine tip is 2019ft AHD, and when the MOC of 1000ft is applied the result is 3019ft AHD. As the lowest LSALT is 3500ft on W657, none of the LSALTs are impacted by the SHWF WEF.

6.9 Impact on Victorian Emergency Services Aerial Operations

6.9.1 Victorian Air Ambulance

Wind turbines and wind farms are an obstacle that has to be considered during Helicopter Air Ambulance operations. All operations are subject to dynamic risk assessment and if the risk is considered too great the operation is modified or cancelled. The pilot in command has the ultimate responsibility for the safety of the aircraft. Fixed wing Air Ambulance operations are conducted in accordance with the IFR. Obstacle clearance is assured by the published or calculated LSALT for the route to be

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flown. IFR operations at aerodromes with published Instrument Approach Procedures are protected by the minimum safe altitudes specified in the approach procedures. Where there is no instrument approach procedure the aircraft remains not below the LSALT until within 10km of the airport and then proceeds in accordance with VFR. Given that YARA is 26km from the SHWF WEF it will have minimal impact on fixed wing IFR operations into that aerodrome and YBLT has published Instrument Approach Procedures.

6.9.2 Victoria Police Air Wing

Wind turbines and wind farms, such as the SHWF WEF, are an obstacle that has to be considered during Police Air Wing operations. All operations are subject to dynamic risk assessment and if the risk is considered too great the operation is modified or cancelled. The pilot in command has the ultimate responsibility for the safety of the aircraft.

6.9.3 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 fire 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, power lines, houses) and specific hazards, such as the SHWF WEF, associated with aerial firefighting or other specialist low level flying operations.

6.9.4 Aerial Fire Fighting

“It is important to remember that aircraft alone do not extinguish fires.”17 Concern about the inability to utilise aerial firefighting in wind farm areas is often expressed. 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 view wind turbines and wind farms to be ‘just another hazard’ that is considered in the risk management process associated with aerial firefighting. The Australian Fire and Emergency Service Authorities Council (AFAC) Wind Farms and Bushfire Operations Position Paper 30 October 2014 (Appendix D) 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

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

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risks.”18 The AFAC paper supported submissions made by the State rural firefighting agencies from Tasmania, South Australia, Victoria, New South Wales and Western Australia to the recent Senate Select Committee on Wind Turbines. In these submissions the agencies make the point that firefighting aircraft operate to the VFR 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 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.19” 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 contained in Appendix C. Additionally, in the CFA Emergency Management Guidelines for Wind Energy Facilities - May 2015, the CFA recommends: “… … a minimum distance between turbines of 300 metres. This provides adequate distance for aircraft to operate around a wind energy facility given the appropriate weather and terrain conditions. 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.”20

6.9.5 Ground Based Fire Fighting

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.

18 AFAC Wind Farms and Bushfire Operations Position version 2.0 30 October 2014, page 2 19 SA CFS Fact Sheet 10-01, Understanding Aerial Firefighting, March 2015 20 CFA Emergency Management Guidelines for Wind Energy Facilities May 2015 section 2

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6.10 Agricultural Aviation Activities

The Aerial Agricultural Association of Australia opposes wind farm developments unless the developer has (inter alia): ƒ Consulted in detail with local operators; ƒ Received independent expert advice on safety and economic impacts; and ƒ Considered the impacts on the aerial application industry.21 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 property.22”

6.11 Impact on Australian Defence Force (ADF) Operations

Military low level flying operations are rigidly controlled and undertaken by specially trained pilots in military aircraft equipped for low level flight by day or night. In accordance with relevant CASA and Defence requirements the proponent is required to notify the aviation authorities of the existence and detail of the wind farm as a “Tall Structure”23. The Department of Defence reminds proponents of wind farms about the need to advise RAAF AIS of structures which are 30m or taller within 30km of an aerodrome; or 40m or taller elsewhere. This is particularly applicable to meteorological monitoring towers which are, by their nature, difficult to see.

6.12 Topographical and Weather Issues

Aircraft operating under 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 clear of obstacles and terrain. Otherwise CAR 157 states (in part) that an aircraft operating under VFR must not fly lower than 500ft (152m) 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: ƒ Due stress of weather or any other avoidable cause it is essential that a lower height be maintained; or ƒ It is engaged in approved low flying private or aerial work; or ƒ 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 ƒ It is undertaking a baulked approach; or ƒ It is flying in the course of actually taking-off or landing at an aerodrome.

21 http://www.aerialag.com.au/ResourceCenter/Policies.aspx 22 Expert opinion from interviews with Aerial Agricultural operators 23 CASA AC 139.08 Reporting of Tall Structures

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In this regard, the AIP states that a pilot of a fixed wing aircraft operating under VFR (by day in Class G airspace24) must have 5 km 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 500ft (152m) above the terrain or obstacles. As noted in paragraph 6.4 the flying schools at YBLT conduct training in the general area to the east of the SHWF WEF, consequently such training flights would normally be outside its boundaries. It is also noted that the Western Highway and the Ballarat/Ararat railway line to the north, and the Ballarat to Skipton road to the south, are sufficiently clear of the SHWF WEF to enable a VFR pilot caught by low cloud to navigate safely by using them as a visual guide.

6.13 NASF Guidelines

The National Airports Safeguarding Advisory Group (NASAG) published the National Airports Safeguarding Framework (NASF) in July 2012.25 NASF – 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.

6.13.1 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 SHWF WEF must be reported to CASA and the RAAF in accordance with AC 139-08(1) Reporting of Tall Structures.

24 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. 25 Department of Infrastructure and Regional Development, The National Airports Safeguarding Framework, 15 July 2012; available at https://infrastructure.gov.au/aviaiton/environmental/airport_safeguarding’nasf/nasf_principles_guidellines

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6.13.2 Risk Assessment

These turbines, being greater than 150m tall and within 30km (16.2nm) of the registered aerodrome YARA , could be considered as a hazardous obstacle and be subject to a risk assessment. The NASF Guideline D 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. 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.

6.13.3 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. 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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6.13.4 Risk Assessment Outcome

The SHWF WEF: - ƒ Does not penetrate any OLS or PANS-OPS prescribed airspace; ƒ Poses a LOW risk to the operation of aircraft in the area; and ƒ Therefore is not a hazard to aircraft safety. In accordance with NASF Guideline D section 27, sub-paragraph (c) (paragraph 6.13.2 above), the SHWF WEF is not a hazard to aircraft safety.

6.14 Qualitative Risk Assessment Summary

The assessed level of risk is summarised in Table 6.4 below.

Risk Element Assessed Comment Level of Risk Aerodrome Operations LOW The aerodromes in the vicinity of the SHWF WEF are at least 14nm distant One of these aerodromes has published instrument approaches which are not impacted by the proposed SHWF WEF Aircraft Landing Area Operations LOW Operations into ALA, by definition, are conducted in accordance with the VFR. It is the responsibility of the pilot in command to ascertain the suitability of the ALA for the proposed aviation operation Known Highly Trafficked Routes LOW Flying schools from Ballarat use the area between Ballarat, Mt Emu, Beaufort, and Clunes for flying training. These flights normally have an Instructor on board and are generally outside the SHWF WEF. Published Air Routes LOW No infringement of published LSALT Restricted Airspace LOW None identified in the vicinity. Promulgated Flying Training Areas LOW None identified in the vicinity. Instrument Flight Training LOW IFR flight training at Yarrowee (YWE) radio navigation Yarrowee (YWE) Navaids aid, located 13nm (24km) SE of SHWF WEF. There is a published Instrument Approach associated with the navigation aid. The MSA and holding for this approach is 4000ft which is well above the 3019ft safety altitude of the highest turbine tip. The training approach must be used in day VMC only and any circling must be within 3nm of the navigation aid. The pilot in command is responsible for maintaining visual separation with all obstacles Night Flying LOW Protected by LSALTs Recreational/Commercial Flying LOW Sufficiently distant from Registered or Certified aerodromes.

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Risk Element Assessed Comment Level of Risk GA Pilot Training LOW Flying schools from Ballarat use the area between Ballarat, Mt Emu, Beaufort, and Clunes for flying training. These flights normally have an Instructor on board and are outside the SHWF WEF. Aerial Agricultural Operations LOW Risk in the immediate vicinity is MEDIUM Air Ambulance Operations LOW Risk in the immediate vicinity is MEDIUM Police Aviation Operations LOW Risk in the immediate vicinity is MEDIUM Fire Fighting Operations LOW Risk in the immediate vicinity is MEDIUM Weather and Visibility Issues LOW Risk in the vicinity during periods of inclement weather causing marginal VMC and where a pilot “pushes on” could be considered MEDIUM due to the terrain. There are major highways that provide sufficient visual reference to keep pilots clear of the SHWF WEF and therefore mitigate the risk to LOW. Table 6.4 Qualitative Risk Assessment Summary The SHWF WEF poses a LOW risk to aviation in the area because: - ƒ It does not penetrate the OLS or PANS – OPS for either YBLT or YARA: ƒ It does not penetrate any air route LSALT; ƒ It is beyond “the vicinity of the aerodrome” at YBLT (33km distant); ƒ It is 23km distant from YARA, however there is an existing unlit WEF26 between the SHWF WEF and YARA; ƒ There are no promulgated flying training areas or highly trafficked routes; ƒ There are easily identifiable highways and railways to guide a VFR pilot, caught through poor airmanship by low cloud, safely clear. As shown in table 6.4, the risk to aviation from the SHWF WEF is LOW. Consequently no further risk mitigation is required and the SHWF WEF is therefore not a hazard to aircraft safety and will not be of operational significance to aviation activity. The QRA shows that the increased tip height and the reduced number of the turbines proposed for the already approved SHWF WEF will not be of operational significance or be a hazard to aircraft safety.

26 Challicum Hills WEF is marked on both the Hamilton WAC and the Melbourne VNC

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7. OBSTACLE LIGHTING ASSESSMENT

7.1 NASF Guideline D - Managing Risk to Aviation Safety of Wind Turbine Installations (Wind Farms) and Wind Monitoring Towers

These guidelines refer to large wind turbines being sufficiently conspicuous, by day, due to their shape and size provided the turbine is of a contrasting colour to the background; as noted in clause 30 below. 30 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. Other colours are acceptable, unless the colour of the turbine is likely to blend in with the background. Clauses of the guidelines relevant to this Obstacle Lighting Review indicate: 33 Where a wind turbine 150m or taller in height is proposed away from aerodromes, the proponent should conduct an aeronautical risk assessment. 34 The risk assessment, to be conducted by a suitably qualified person(s), should examine the effect of the proposed wind turbines on the operation of aircraft. The study must be submitted to CASA to enable an assessment of any potential risk to aviation safety. CASA may determine that the proposal is: x hazardous, but that the risks to aircraft safety would be reduced by the provision of approved lighting and/or marking; or x not a hazard to aircraft safety. The QRA (in sections 6.13.2 and 6.14 above) shows that the SHWF WEF poses a LOW risk and is therefore not a hazard to aircraft safety.

7.2 Requirement for Obstacle Lighting

In line with the NASF Guideline D and the findings of the QRA (see 6.13.2 and 6.14 above), obstacle lighting is not considered necessary because the assessed risk to aviation safety is LOW and therefore no additional mitigation is required. It is noted that the Instrument Approach Procedure Plates 27 for Ballarat RNAV-Z RWY 18 and NDB RWY 36, dated 6 MAR 2014, have an editorial note that the nearby wind farm obstacle lighting has been decommissioned. This decommissioning occurred in 2010. It is also noted that there is an existing unlit wind farm 28 between the SHWF WEF and YARA which is marked on the appropriate aeronautical charts.

27 Aeronautical Information Publication, Departure and Approach Procedures EAST Amendment 139, 29 May 2014 28 Challicum Hills WEF is marked on both the Hamilton WAC and the Melbourne VNC

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8. METEOROLOGICAL MONITORING MASTS

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 8.1 below shows how difficult it is to see such a Meteorological Monitoring Mast from the ground.

Figure 8.1 – A Meteorological Monitoring Mast photographed from the ground 29 In line with the NASF and FAA recommendations below wind farm proponents should ensure meteorological monitoring masts are marked with a minimum of the top third being painted in contrasting colours and marker balls or high visibility flaps are used to mark the outer guy wires. These markings need to be maintained to ensure their efficacy.

8.1.1 NASF Guideline – Marking of Meteorological Monitoring Masts

The NASF guideline also refers to the marking and lighting of wind monitoring towers. The relevant points are: These structures 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: x 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; x Marker balls, high visibility flags or high visibility sleeves

29 Photo by the Author: - met tower in Western Victoria

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placed on the outer guy wires; x Ensuring the guy wire ground attachment points have contrasting colours to the surrounding ground and vegetation; or x A flashing strobe light during daylight hours.

8.1.2 Federal Aviation Administration – Marking of MET towers

It is noted that the Federal Aviation Administration (FAA) has issued, on 24 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, the guy wires have high visibility balls or sleeves and that the markings are replaced when faded or otherwise deteriorated.30

8.1.3 SHWF WEF Met Towers

SHWFPL advise that there are 6 permanent and 1 temporary meteorological monitoring masts installed within the SHWF WEF and that their locations have been reported in accordance with AC 139 - 08 (1). These masts have been installed with guy anchor markers (approximately 2m in length) and visibility markers/aviation balls on the guy wires near the top of the tower. This is in accordance with the above guidelines for marking met towers.

9. REPORTING OF TALL STRUCTURES

CASA has published AC 139-08(0) April 2005 Reporting of Tall Structures which details the requirements for reporting structures of 30m or more within 30km of an aerodrome or of 45m or above elsewhere. The AC provides a reporting form and format, the reporting address and details the available methods of reporting. The reporting format should be used by SHWFPL to report the SHWF WEF, from the start of construction to completion to ensure its inclusion in the AIP and World Aeronautical Charts. Information on tall structures is held by the Royal Australian Air Force Aeronautical Information Service in a database. This information is provided to a range of aviation organisations so that the tall structures can be identified on aeronautical charts. The information is also provided for use by mapping agencies.

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

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Intentionally Left Blank

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APPENDIX A

Airservices Australia Aviation Assessments for Wind Farm Developments 19 August 2014

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APPENDIX A Airservices Australia Aviation Assessments for Wind Farm Developments 19 August 2014

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APPENDIX B

Stockyard Hill Wind Farm Site Identification, Coordinates and Elevations

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APPENDIX B

Stockyard Hill Wind Farm Site Identification, Coordinates and Elevations

Note that Turbine IDs are not continuously numbered

Tip Height Tip Height ID Easting Northing Height m AHD ft AHD 180 m Multiplier Turbine 3.2808 1 696970.00000000000 5853262.00000000000 353.29 533.29 1750 2 696914.00000000000 5852640.00000000000 352.66 532.66 1748 3 703087.00000000000 5852543.00000000000 409.00 589.00 1932 4 697829.00000000000 5852592.00000000000 347.28 527.28 1730 5 697453.00000000000 5852410.00000000000 351.91 531.91 1745 6 703596.00000000000 5852201.00000000000 410.32 590.32 1937 7 699827.00000000000 5851980.00000000000 364.44 544.44 1786 8 702658.00000000000 5852068.00000000000 404.93 584.93 1919 9 704067.00000000000 5852005.00000000000 416.00 596.00 1955 10 704594.00000000000 5851892.00000000000 426.00 606.00 1988 11 701970.00000000000 5851867.00000000000 394.38 574.38 1884 12 699269.00000000000 5851669.00000000000 341.60 521.60 1711 13 702934.00000000000 5851497.00000000000 378.71 558.71 1833 14 702961.00000000000 5850946.00000000000 368.42 548.42 1799 15 704533.00000000000 5850422.00000000000 405.00 585.00 1919 16 708058.00000000000 5849561.00000000000 391.97 571.97 1877 17 711186.00000000000 5849226.00000000000 391.59 571.59 1875 18 712244.00000000000 5849137.00000000000 408.92 588.92 1932 19 710225.00000000000 5849113.00000000000 386.58 566.58 1859 20 708248.00000000000 5849092.00000000000 380.26 560.26 1838 21 709736.37560000000 5849070.30100000000 367.72 547.72 1797 22 711174.00000000000 5848720.00000000000 427.76 607.76 1994 23 707771.00000000000 5848564.00000000000 413.80 593.80 1948 24 709861.00000000000 5848586.00000000000 370.76 550.76 1807 25 708283.00000000000 5848579.00000000000 371.15 551.15 1808 26 710426.00000000000 5848610.00000000000 374.90 554.90 1821 27 712356.00000000000 5848444.00000000000 401.00 581.00 1906 28 707279.00000000000 5848336.00000000000 387.50 567.50 1862 29 706700.00000000000 5848304.00000000000 367.84 547.84 1797 30 708518.00000000000 5848087.00000000000 365.29 545.29 1789

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Tip Height Tip Height ID Easting Northing Height m AHD ft AHD 31 707943.00000000000 5847939.00000000000 394.53 574.53 1885 32 709263.00000000000 5847903.00000000000 363.66 543.66 1784 33 707415.00000000000 5847830.00000000000 392.03 572.03 1877 34 709970.00000000000 5847874.00000000000 371.06 551.06 1808 35 707000.00000000000 5847645.00000000000 393.78 573.78 1882 36 708463.00000000000 5847573.00000000000 365.74 545.74 1790 37 706643.00000000000 5847404.00000000000 396.90 576.90 1893 38 706178.00000000000 5847399.00000000000 398.68 578.68 1899 39 707325.00000000000 5847306.00000000000 374.26 554.26 1818 40 705657.00000000000 5847248.00000000000 391.03 571.03 1873 41 706020.00000000000 5846821.00000000000 381.15 561.15 1841 42 710100.92480000000 5844908.23600000000 365.00 545.00 1788 43 710626.00000000000 5844786.00000000000 371.69 551.69 1810 44 711386.00000000000 5844646.00000000000 380.25 560.25 1838 45 709880.00000000000 5844452.00000000000 359.94 539.94 1771 46 711996.00000000000 5844324.00000000000 380.60 560.60 1839 47 710924.00000000000 5844017.00000000000 365.44 545.44 1789 48 713180.00000000000 5844022.00000000000 354.14 534.14 1752 49 712567.00000000000 5844036.00000000000 365.58 545.58 1790 50 711505.00000000000 5843838.00000000000 372.96 552.96 1814 51 704971.00000000000 5843907.00000000000 387.50 567.50 1862 52 712086.00000000000 5843715.00000000000 372.23 552.23 1812 53 701943.00000000000 5843592.00000000000 353.37 533.37 1750 54 704167.00000000000 5843295.00000000000 369.93 549.93 1804 55 711274.00000000000 5843205.00000000000 363.90 543.90 1784 56 711783.00000000000 5843045.00000000000 356.49 536.49 1760 57 703683.00000000000 5843029.00000000000 388.00 568.00 1863 58 703127.00000000000 5842919.00000000000 377.99 557.99 1831 59 702608.00000000000 5842843.00000000000 366.21 546.21 1792 60 710958.00000000000 5842681.00000000000 355.66 535.66 1757 61 703463.00000000000 5842528.00000000000 382.12 562.12 1844 62 703968.00000000000 5842414.00000000000 386.29 566.29 1858 63 704476.00000000000 5842359.00000000000 387.00 567.00 1860 64 702900.00000000000 5842225.00000000000 372.61 552.61 1813 65 702454.00000000000 5841969.00000000000 371.66 551.66 1810 66 701795.00000000000 5841798.00000000000 360.50 540.50 1773 67 703485.00000000000 5841740.00000000000 387.26 567.26 1861 68 701242.00000000000 5841562.00000000000 358.00 538.00 1765 69 703965.00000000000 5841397.00000000000 392.69 572.69 1879

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Tip Height Tip Height ID Easting Northing Height m AHD ft AHD 70 702129.00000000000 5841376.00000000000 369.28 549.28 1802 71 702763.00000000000 5841264.00000000000 379.66 559.66 1836 72 703420.00000000000 5841212.00000000000 388.32 568.32 1865 73 704651.00000000000 5840903.00000000000 435.50 615.50 2019 74 701686.00000000000 5840831.00000000000 372.57 552.57 1813 75 701107.00000000000 5840803.00000000000 361.36 541.36 1776 76 704140.00000000000 5840608.00000000000 400.88 580.88 1906 77 703046.00000000000 5840522.00000000000 388.55 568.55 1865 78 702406.00000000000 5840754.00000000000 379.08 559.08 1834 79 703567.00000000000 5840557.00000000000 393.47 573.47 1881 80 701345.00000000000 5840315.00000000000 363.79 543.79 1784 81 702091.00000000000 5840217.00000000000 374.21 554.21 1818 82 698244.00000000000 5840083.00000000000 334.18 514.18 1687 83 703881.00000000000 5839976.00000000000 399.58 579.58 1901 84 699070.00000000000 5839935.00000000000 340.47 520.47 1708 85 700969.00000000000 5839898.00000000000 364.19 544.19 1785 86 702753.00000000000 5839828.00000000000 382.50 562.50 1845 87 697918.00000000000 5839649.00000000000 328.17 508.17 1667 88 707918.00000000000 5839334.00000000000 363.05 543.05 1782 89 701554.05800000000 5839757.17530000000 366.11 546.11 1792 90 709710.00000000000 5839595.00000000000 356.36 536.36 1760 91 703445.00000000000 5839409.00000000000 392.01 572.01 1877 92 700750.00000000000 5839386.00000000000 358.47 538.47 1767 93 699995.00000000000 5839374.00000000000 354.47 534.47 1753 94 699322.00000000000 5839251.00000000000 350.50 530.50 1740 95 702311.00000000000 5839261.00000000000 372.50 552.50 1813 96 698366.00000000000 5839207.00000000000 340.50 520.50 1708 97 700448.00000000000 5838975.00000000000 365.08 545.08 1788 98 702915.00000000000 5838918.00000000000 379.16 559.16 1834 99 701099.00000000000 5838869.00000000000 363.35 543.35 1783 100 698765.00000000000 5838888.00000000000 345.93 525.93 1725 101 699878.00000000000 5838908.00000000000 353.26 533.26 1750 102 709035.00000000000 5838816.00000000000 357.72 537.72 1764 103 699336.00000000000 5838700.00000000000 349.00 529.00 1736 104 702305.00000000000 5838649.00000000000 367.07 547.07 1795 105 700212.00000000000 5838479.00000000000 355.78 535.78 1758 106 701753.00000000000 5838374.00000000000 359.50 539.50 1770 107 700028.00000000000 5837050.00000000000 326.86 506.86 1663 108 700797.00000000000 5836663.00000000000 329.21 509.21 1671

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Tip Height Tip Height ID Easting Northing Height m AHD ft AHD 109 713443.00000000000 5834084.00000000000 360.56 540.56 1773 110 714394.00000000000 5834054.00000000000 347.76 527.76 1731 111 712717.00000000000 5834028.00000000000 388.98 568.98 1867 112 713904.00000000000 5833871.00000000000 357.56 537.56 1764 113 712257.00000000000 5833760.00000000000 393.33 573.33 1881 114 713079.00000000000 5833676.00000000000 387.90 567.90 1863 115 711050.00000000000 5833660.00000000000 364.60 544.60 1787 116 714504.00000000000 5833560.00000000000 346.37 526.37 1727 117 713566.00000000000 5833496.00000000000 371.51 551.51 1809 118 710612.00000000000 5833401.00000000000 352.46 532.46 1747 119 714973.00000000000 5833364.00000000000 342.08 522.08 1713 120 711409.00000000000 5833292.00000000000 412.15 592.15 1943 121 712275.00000000000 5833249.00000000000 420.00 600.00 1968 122 713114.00000000000 5833173.00000000000 396.58 576.58 1892 123 714056.00000000000 5833144.00000000000 356.11 536.11 1759 124 711819.00000000000 5832989.00000000000 394.87 574.87 1886 125 713580.00000000000 5832976.00000000000 373.91 553.91 1817 126 715577.00000000000 5832941.00000000000 347.89 527.89 1732 127 709511.00000000000 5832837.00000000000 335.71 515.71 1692 128 712736.00000000000 5832837.00000000000 400.94 580.94 1906 129 712247.00000000000 5832704.00000000000 399.48 579.48 1901 130 709045.00000000000 5832608.00000000000 334.19 514.19 1687 131 716240.00000000000 5832587.00000000000 343.90 523.90 1719 132 713303.00000000000 5832554.00000000000 377.17 557.17 1828 133 712846.00000000000 5832338.00000000000 379.95 559.95 1837 134 712356.00000000000 5832208.00000000000 373.10 553.10 1815 135 709467.00000000000 5831817.00000000000 336.46 516.46 1694 136 712485.00000000000 5831487.00000000000 361.22 541.22 1776 137 711536.00000000000 5830952.00000000000 347.30 527.30 1730 138 712393.00000000000 5830780.00000000000 347.90 527.90 1732 139 713076.00000000000 5830672.00000000000 351.63 531.63 1744 140 713649.00000000000 5830388.00000000000 351.77 531.77 1745 141 714540.00000000000 5830355.00000000000 350.89 530.89 1742 142 712323.00000000000 5830287.00000000000 341.16 521.16 1710 143 712910.00000000000 5830158.00000000000 346.33 526.33 1727 144 713936.00000000000 5829969.00000000000 348.50 528.50 1734 145 714438.00000000000 5829859.00000000000 342.29 522.29 1714 146 710355.00000000000 5844267.00000000000 360.51 540.51 1773

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Tip Height Tip Height ID Easting Northing Height m AHD ft AHD 147 701578.00000000000 5839096.00000000000 363.56 543.56 1783 148 699605.00000000000 5839811.00000000000 347.06 527.06 1729 149 698674.00000000000 5839618.00000000000 341.05 521.05 1709

Highest Turbine Tip is T73

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APPENDIX C

South Australian Country Fire Service Understanding Aerial Firefighting

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APPENDIX C

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APPENDIX D

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

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INTENTIONALLY LEFT BLANK

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APPENDIX D

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APPENDIX E

Airservices Australia Response to the AIS

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APPENDIX E

Airservices Australia Response to AIS

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INTENTIONALLY LEFT BLANK

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APPENDIX F

Department of Defence Response to the AIS

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APPENDIX F

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APPENDIX G

Glossary of Terms

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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 aviation 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.

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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.

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 are 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.

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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 Transport (DoIT).

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.

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

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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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