Telecommunications Impact Assessment White Rock Wind Farm – 2010 Author: Anthony Micallef BE (Electrical) EPURON PTY LTD (ABN 70 104 503 380) Level 11, 75 Miller St NORTH SYDNEY, NSW 2060 Office: (02) 8456 7400 Int’l: +61 (2) 8456 7400 Fax: (02) 9922 6645 Int’l: +61 (2) 9922 6645 www.epuron.com.au Telecommunication/ and Electromagnetic Interference Impact Assessment – White Rock Wind Farm TABLE OF CONTENTS 1 Executive summary ................................................................................................................................3 2 Glossary of technical terms.....................................................................................................................4 3 Existing environment..............................................................................................................................5 3.1 4 5 6 Television and radio broadcast services..................................................................................................7 4.1 Existing services and facilities .....................................................................................................7 4.2 Television broadcasting................................................................................................................9 4.2.1 Interference and impact analysis..............................................................................................9 4.2.2 House and television tower locations ....................................................................................12 4.3 Mitigation measures ...................................................................................................................13 4.4 Satellite pay television................................................................................................................13 4.5 Radio broadcasting .....................................................................................................................13 4.6 MF sound broadcasting ..............................................................................................................14 Mobile phone services ..........................................................................................................................14 5.1 Existing services and facilities ...................................................................................................14 5.2 Interference and impact analysis ................................................................................................16 5.3 Mitigation measures ...................................................................................................................17 Radio communication services .............................................................................................................17 6.1 Existing services and facilities ...................................................................................................17 6.2 Interference and impact analysis ................................................................................................20 6.3 Radio communication links ........................................................................................................21 6.4 Other radio communication ........................................................................................................24 6.4.1 Two way mobile ....................................................................................................................24 6.4.2 CB radio.................................................................................................................................24 6.4.3 Wireless broadband ...............................................................................................................25 6.5 7 Impact assessment ........................................................................................................................7 Mitigation measures ...................................................................................................................25 Electric and magnetic fields..................................................................................................................25 7.1 What are electric and magnetic fields?.......................................................................................25 7.2 When do electric and magnetic fields occur? .............................................................................25 7.3 What are the electromagnetic field implications of wind farming?............................................26 7.4 Mitigation measures ...................................................................................................................27 8 Conclusion ............................................................................................................................................27 9 Turbine co-ordinates .............................................................................................................................27 10 Fresnel zone calculation ..................................................................................................................29 11 Correspondence...............................................................................................................................30 2 Telecommunication/ and Electromagnetic Interference Impact Assessment – White Rock Wind Farm 1 EXECUTIVE SUMMARY The objective of this report is to investigate the potential impacts of the White Rock wind farm on existing telecommunication services in the vicinity of the proposal and to propose appropriate mitigation strategies for any impacts identified. An assessment of possible electric and magnetic fields associated with wind farms and their implications on human health is also presented. Telecommunication services, including television and radio broadcasts, mobile phone services and point to point microwave radio communication services occur in proximity to population centres and often utilise the same ridgelines that provide optimum locations for wind turbines. Theoretically, as with any large structure, wind turbines have the potential to cause interference with such signals. In general, VHF and UHF frequency band radio signals and digital voice based technologies such as GSM mobile are essentially unaffected by wind turbines. This includes land mobile repeaters, radio, the audio component of analogue television and mobile phones. 1 For broadcast signals which are usually omni-directional (or point to area), interference can generally be avoided by locating wind turbines distant from the broadcast tower. A clearance of at least 500m is recommended, although a distance of 1km is preferred. 2 No broadcast or communications towers have been identified within 500m of the White Rock wind farm project. Therefore the development of the proposed wind project is not expected to have any widespread adverse backscatter affect from being near to broadcast or communications towers. Aviation navigation services such as radar may also potentially be affected by wind turbines depending on the location of the wind farm with respect to the position of radar installations and airports. This issue is likely to be overcome in the future, as aviation authorities across the world increasingly move towards the use of multilateration (MLAT) technology. At the time of writing, no objection to the proposal has been raised by Airservices Australia. Following a review of the communication services near the wind farm site, the nature of potential interference and consultation with license holders and service providers, it is considered that the proposed wind farm would have minimal impact on existing telecommunications and aviation navigation services. Where applicable, mitigation strategies are proposed to ensure any identified impacts can be managed appropriately. The electromagnetic fields associated with generation and export of electricity from a wind farm does not pose a significant threat to public health. Consequently, no adverse electromagnetic interference issues are anticipated from the wind farm. 1 http://www.dungog.nsw.gov.au/files/2142/File/GreenpowerEMIAnalysisIssue.pdf 2 ibid 3 Telecommunication/ and Electromagnetic Interference Impact Assessment – White Rock Wind Farm 2 GLOSSARY OF TECHNICAL TERMS ABA ACMA Band 111 CB Radio CDMA EMI FM Fresnel Clearance GSM ITU LF MF UHF UHF Channels VHF VHF Channels Australian Broadcasting Authority Australian Communications & Media Authority VHF TV Channels 5A - 12 Citizens Band Radio Code Division Multiple Access cellular mobile system Electromagnetic Interference Frequency Modulation Clearance to obstructions from the ray line on a radio path which does not produce any additional loss above free space loss Global Systems Mobiles International Telecommunications Union Low Frequency Medium Frequency Ultra High Frequency (300MHz - 3GHz) TV Channels 28 - 69 (526 - 820 MHz) Very High Frequency (30MHz - 300MHz) TV Channels 0 to 12 (45 - 230 MHz) 4 Telecommunication/ and Electromagnetic Interference Impact Assessment – White Rock Wind Farm 3 EXISTING ENVIRONMENT Figure 1 - White Rock wind farm site locality 5 Telecommunication/ and Electromagnetic Interference Impact Assessment – White Rock Wind Farm The White Rock wind farm is located approximately 20km west of Glen Innes, NSW (between Glen Innes and Inverell) as shown in Figure 1. A review of the telecommunication technologies in use in the vicinity of the proposed White Rock wind farm identified the following: ¾ TV and radio broadcasting ¾ Mobile phone services provided by telecommunication companies ¾ Radio communication systems, including point to point microwave links, licensed by the Australian Communications and Media Authority (ACMA) ¾ Other radio links including mobile radio, CB radio; and ¾ Aircraft navigation systems Electromagnetic interference (EMI) has the potential to cause degradation or total loss of signal strength and may cause poor TV reception and/or “ghosting” effects. EMI may also result in a reduction in the coverage of mobile phone, radio and aircraft navigation communications in certain instances. There are three principal mechanisms by which wind turbines may cause EMI: reflection or scattering, diffraction and near field effects. 3 Reflection or scattering When a signal sent between a transmitter and receiver becomes obstructed by an object located within the path of a signal, reflection and/or scattering may occur. If the rotating blade of a wind turbine receives a primary transmitted signal, a scattered time delayed (or out of phase) signal may be produced and transmitted to the receiver. The out of phase signal will be distorted in relation to the primary signal, causing EMI. 4 Diffraction In some instances when an object is located in the path of a signal wave front, the object can both reflect and absorb the signal. This phenomenon is commonly referred to as diffraction. 5 Near field effects Wind turbines may cause interference to radio signals due to the electromagnetic fields emitted by the generator and the switching components within the turbine nacelle. This is referred to as a near field effect. 6 Due to advances in technology and compliance with the Electromagnetic Emission Standard, EN 61000-6-4 (AS/NZ 4251.2:1999) Emission standard for industrial environments, modern wind turbines will not cause active EMI due to near field effects. The level of EMI produced by a wind turbine due to reflection or scattering, diffraction and near field effects is dependant on a number of factors, including placement of the wind turbine in relation to the signal path/s; the signal frequency; the characteristics / composition of the wind turbines rotor blades; the receiver characteristics; and the propagation characteristics of the radio wave in the local atmospheric conditions. 7 3 D. F. Bacon, A Proposed Method for Establishing an Exclusion Zone around a Terrestrial Fixed Link outside of which a Wind Turbine will cause Negligible Degradation of the Radio Link, Radiocommunications Agency UK Report Ver 1.1, 28 Oct 2002 4 URS Woodlawn Wind Farm Environmental Impact Statement 2004 5 Ibid. 6 Ibid. 7 Ibid. 6 Telecommunication/ and Electromagnetic Interference Impact Assessment – White Rock Wind Farm While the site proposed for the development of the wind farm is a rural area, a number of communications links and broadcast networks are present in the surrounding region. As with any large structure, there may be circumstances where wind turbines can cause disruption to the electromagnetic signals used in a variety of commonly used radar, navigation and telecommunications services. The following approach was adopted to identify the impact of the proposal on telecommunications: ¾ Identify radio license holders within a 25km radius of the proposed wind farm site, and point to point microwave radio links in the vicinity of the site, using information sourced from the ACMA RADCOM database 8 ; ¾ Provide notification of the wind farm proposal and seek comments from each license holder identified via the ACMA RADCOM database within a 25km radius of the site; ¾ Record and review all responses received to identify any issues raised by license holders; ¾ Discuss any issues raised with relevant license holder with the aim to resolve or identify mitigation options; ¾ Carry out an assessment of the “Fresnel zone” associated with each fixed point to point microwave communications link crossing the site; ¾ Determine appropriate exclusion zones for proposed turbine layout based on Fresnel zone calculations and advice from relevant license holders; ¾ Confirm that all turbines (including blades) are located outside the calculated exclusion zone; ¾ Determine appropriate additional mitigation measures which may be required. 3.1 IMPACT ASSESSMENT The possible impact of the proposed wind farm on the four most common communications services has been investigated separately. These services are television and radio broadcast services, mobile phone services, microwave radio point to point communication services and aircraft navigation services. Any impacts would be confined to the construction and operational phases of the wind farm. Various measures are available to help mitigate potential impacts and are discussed below. 4 TELEVISION AND RADIO BROADCAST SERVICES 4.1 EXISTING SERVICES AND FACILITIES The ACMA issue apparatus licences under the Radio communications Act 1992. The ACMA is the federal government authority responsible for regulation and management of the radio communications spectrum. It was formed in July 2005 by the merging of Australian Broadcasting Authority (ABA) and the Australian Communications Authority (ACA). The ACMA authorises licensees to operate radio communications devices such as transmitters and receivers. In effect, they are licences to use specific segments of the radiofrequency spectrum for particular purposes. A system of apparatus licence types are used to apply common licence conditions and fee structures to categories of radio communications service. 8 April 2010 data 7 Telecommunication/ and Electromagnetic Interference Impact Assessment – White Rock Wind Farm The ACMA RADCOM database lists the following broadcasters for television and radio, under postcode 2370, Glen Innes, NSW. Television broadcasting Northern New South Wales TV1: ABC, NBN, NEN, NRN and SBS Remote Central and Eastern Australia TV1: ABC, IMP and SBS Remote Central and Eastern Australia TV2: QQQ Radio broadcasting Deepwater RA1: 2CBD Inverell RA1: 2ABCRN, 2ABCRR, 2GEM, 2GL, 2NZ, 2PNN Remote Commercial Radio Service North East Zone RA1: 2ABCRN, 2ABCRR, 2ABCRN, 4ABCRR, 4BRZ, 4JK, 4QCC, 4RBL, 4TI, 4WP and ABC. The closest transmitter of television programs is at Carpenters Hill located about 4 kilometres North West of Glen Innes. Transmission from Carpenters Hill is at low power (400 watts) and only serves Glen Innes and its immediately surrounding areas. Most properties immediately west of Waterloo Range do not receive the transmission from Carpenters Hill due to the topographic shielding by Waterloo Range. Residents to the east of Waterloo Range have indicated that they have good reception from the Carpenters Hill transmitter. 9 Mt Dowe (Mt Kaputar), near Narrabri has strong transmission (72 kW to 600kW). The quality of reception of the Mt Dowe signals was much poorer in the Wellingrove Valley. Nevertheless, some residents in parts of Wellingrove Valley indicate that they receive signals from Mt Dowe. Reception of signals from Mt Dowe is expected to be poor immediately to the east of Waterloo Range and that area is more likely to use the Carpenters Hill service. 10 Inverell also has a local television service that transmits at low power (25, 50 and 600 watts). The four Inverell channels transmitted at 600 watts were able to be received on top of Waterloo Range. However, these were not detected during brief testing at two locations in Wellingrove valley. The Inverell channels are unlikely to be received to the east of Waterloo Range. 11 The Armidale source broadcasts at high power ranging from 30kW to 120kW. Signal strength measurements undertaken on the top of Waterloo Range indicated that Armidale signals are not well received at the top of Ross Hill. This is considered to be due to the elevated area of Ben Lomond that presents a physical barrier to these signals. 12 Satellite based television services are also received at various locations throughout the area. These services may either be used where local services are not able to be received or may be accessed as additional program content to complement local services. They are not subject to the same topographic screening that can affect the land based TV transmissions. Due to the distance of residences from the wind farm it is very unlikely that satellite based television services would be subject to interference due to the wind farm’s operation. 13 9 Glen Innes Wind Farm Environmental Assessment – Telecommunications interference October 2008, Connell Wagner. 10 Glen Innes Wind Farm Environmental Assessment – Telecommunications interference October 2008, Connell Wagner 11 ibid 12 ibid 13 ibid 8 Telecommunication/ and Electromagnetic Interference Impact Assessment – White Rock Wind Farm Transmitter Location Broadcaster Call Sign / Channel Band Frequency (MHz) Carpenters Hill (mainly received east of Waterloo Range) NBN NBN41 UHF 618.198 Southern Cross Ten NRN44 UHF 638.198 Prime NEN47 UHF 660.198 ABC ABUN50 UHF 681.198 SBS SBS53 UHF 702.198 ABC (digital) ABUN59 UHF 746.5 SBS (digital) SBS65 UHF 788.5 Note: All above channels broadcast with vertical polarisation and at 400 watts. Mt Dowe (mainly received west of Waterloo Range where not limited by topographic screening) ABC ABUN7 VHF 182.24 ABC (digital) Prime ABUN8 VHF 191.625 NEN9 VHF 196.24 Prime (digital) NEN9a VHF 205.625 SBS SBS28 UHF 527.198 SBS (digital) SBS36 UHF 585.5 NBN NBN31 UHF 548.198 Southern Cross Ten NRN34 UHF 569.198 Southern Cross Ten (digital) NRN40 UHF 613.5 Figure 2 - “Free to Air” television broadcast services available around the wind farm facility 14 License holders identified via the ACMA RADCOM database within a 25km radius of the wind farm were notified of the proposal in relation to potential impacts and asked to provide comments. Consultation with Mr Greg Williams, Broadcast Engineering Manager at NBN Television revealed that the translator site at Carpenters Hill (which services Glen Innes town) receives its input signal from the parent site at Mt Dowe (ACMA site ID 35653). The input signal passes through the area proposed for the White Rock wind farm. However on further investigation, the wind turbines locations proposed were shown to be to the south and clear of the transmission corridor and therefore signal interference to the Carpenters Hill translator by the White Rock proposal is not expected. At the time of writing, no other concerns had been raised from the license holders contacted regarding possible impacts to television or radio broadcasting services. The proponent will work with organisations to resolve issues, should any be identified. 4.2 TELEVISION BROADCASTING 4.2.1 Interference and impact analysis Television Interference (TVI) is dependent on a range of factors including environmental factors (topography, direct signal strength, transmitter type, receiver type etc) and wind farm design factors (turbine elevation, rotor size and orientation, speed of rotation, blade material and pitch). 14 Glen Innes Wind Farm Environmental Assessment – Telecommunications interference October 2008, Connell Wagner 9 Telecommunication/ and Electromagnetic Interference Impact Assessment – White Rock Wind Farm TVI caused by the operation of wind turbines is characterised by video distortion, while the audio component of the signal is not affected. 15 Due to the variability of local conditions and the characteristics of antennae used in particular installations, there is a degree of uncertainty regarding predicted levels of interference. The level of TVI may be influenced by a number of factors including: ¾ Where the receiver is located relative to the TV transmitter and the wind farm; ¾ The frequency of the transmitted TV signal; ¾ Whether there are any other tall structures in the vicinity of the receiver; ¾ The direction of the rotor blades and blade material; ¾ The nature of the receiving aerial e.g. design, height, directionality, power. In general, the potential for interference at receiver locations can increase with distance of the receiver from the transmitter, as signal strength decreases with increasing distance from the source. As such, a wind farm in an area of already poor signal strength may potentially have a greater impact on reception than the same wind farm in an area of relatively strong signal strength. In addition, reception in the vicinity of the wind farm can vary with the degree of topographic obstruction of the signal. A wind turbine has the potential to scatter analogue television waves both forward and back. Forward scatter will only occur if a wind turbine is located approximately between the dwelling and the broadcast site. The forward scatter region is as shown in the figure below, and generally does not extend further than 5 km for the worst combination of factors. Interference may extend beyond 5 km if the dwellings are screened from the broadcast tower, but do have line of sight to the wind turbines. The effect of the forward scatter is to potentially cause the brightness of the television picture to vary with the rotation of each blade. Modern television sets usually incorporate Automatic Gain Compensators (AGC) which act to lessen or eliminate variations in picture gain or brightness. 16 Figure 3 - Schematic diagram of potential analogue television signal interference zones around a wind turbine (Courtesy of CanWEA Guidelines V8.0) 15 David E Spera, Wind Turbine Technology, Chapter 9 ASME Press 1994 16 http://www.dungog.nsw.gov.au/files/2142/File/GreenpowerEMIAnalysisIssue.pdf 10 Telecommunication/ and Electromagnetic Interference Impact Assessment – White Rock Wind Farm The zone of potential interference for a wind farm is the resultant total of the effects from the individual turbines. The International Telecommunications Union Recommendation ITU-R BT.805 states that impacts beyond 5 kilometres are unlikely. It also indicates that interference may extend beyond 5km where the receiver location is shielded from the direct signal, but in direct line of sight to the turbine. The form of interference, if experienced, will depend on the relative positions of the wind farm, the transmitting station and the receiver. Television interference can take the form of either a “ghost” image that pulsates horizontally at the “blade pass” frequency or a fluctuation in picture brightness, also at the “blade pass” frequency. 17 There are approximately 57 houses within 5km of the proposed wind farm site. The location of the wind farm with respect to the Carpenters Hill, Mt Dowe, Inverell and Armidale TV transmitters can be seen in Figure 4. 17 Connell Wagner Delta Electricity Gunning Environmental Impact Statement 2004 11 Telecommunication/ and Electromagnetic Interference Impact Assessment – White Rock Wind Farm 4.2.2 House and television tower locations Figure 4 - Houses within 5km of the White Rock wind farm site 12 Telecommunication/ and Electromagnetic Interference Impact Assessment – White Rock Wind Farm It is difficult to assess the likely impact on these specific house locations and once the wind farm is operational it is possible that analogue television reception could be affected at some of these locations unless some form of mitigation is introduced. However, houses further than 5km from the site are unlikely to be affected. 4.3 MITIGATION MEASURES In the design of the project, the proponent will carry out the following mitigation measures to help minimise TVI: ¾ Use of primarily non-metallic turbine blades; ¾ Use wherever practical of equipment complying with the Electromagnetic Emission Standard, AS/NZS 4251.2:1999; Once the wind farm is operational, the proponent will offer to undertake a monitoring program of houses within 5km of the wind farm to determine any loss in television signal strength, if requested by the affected resident. In the event that TVI is experienced by existing receivers in the vicinity of the wind farm, the source and nature of the interference will be investigated by the proponent. Should investigations determine that the cause of the interference is genuinely attributable to the presence of the White Rock wind farm; the proponent will put in place mitigation measures at each of the affected receivers in consultation and agreement with the residents. Notwithstanding the above, specific mitigation measures available are: ¾ Modification to, or replacement of receiving antenna; ¾ Provision of a land line between the affected receiver and an antenna located in an area of favourable reception; ¾ Improvement of the existing antenna system; ¾ Installation of a digital set top box or, ¾ In the event that interference specifically attributable to the wind farm cannot be overcome by other means, negotiating an arrangement for the installation and maintenance of a satellite receiving antenna with the affected landowner may be considered. 4.4 SATELLITE PAY TELEVISION Some homes in the area may have satellite pay TV service antenna installations. Unless a particular subscriber’s antenna reception direction and elevation is aligned with a turbine, no impacts on TV reception are likely. 18 4.5 RADIO BROADCASTING The level of radio broadcast interference experienced can be influenced by a variety of variables including: ¾ Abnormal weather conditions; ¾ Multi-path distortion (reception of a signal directly from a transmitter and also a reflected signal from hills, structures etc.); ¾ Overloading (occurs when an FM receiver receives too strong a signal); 18 Lawrence Derrick & Associates Bannister Wind Farm – Investigation of possible impacts on broadcasting and Radio communication Services September 2003 13 Telecommunication/ and Electromagnetic Interference Impact Assessment – White Rock Wind Farm ¾ Electrical interference from household appliances etc; 4.6 MF SOUND BROADCASTING Wind farm effects on MF radio are highly unlikely and therefore the stations serving the area have not been listed. 19 Overseas and recent local experience indicates that radio reception and the audio component of television reception are unlikely to be affected by operating wind farms. In regard to the Blayney Wind Farm that was commissioned in 2000, testing of radio reception for Council and RFS signals in the area around the operational wind farm showed that radio reception was not affected at the locations tested. The locations tested included situations where the radio signal transmission path passed through the operating wind farm. 20 5 MOBILE PHONE SERVICES 5.1 EXISTING SERVICES AND FACILITIES This section covers GSM services. High frequency point to point communications links used for mobile transmission networks are discussed in the next section: Radio Communication Services. Figures below show the existing local mobile phone coverage from the three providers at the time of writing. (Source: company websites) Figure 5 - Telstra 3G and GSM Coverage 19 Ibid 20 Connell Wagner Glen Innes Wind Farm Environmental Assessment – Telecommunications interference October 2008 14 Telecommunication/ and Electromagnetic Interference Impact Assessment – White Rock Wind Farm Figure 6 - Telstra Next G Network Coverage Figure 7 - Vodafone GSM Network Coverage 15 Telecommunication/ and Electromagnetic Interference Impact Assessment – White Rock Wind Farm Figure 8 - Optus GSM (3G) Coverage 5.2 INTERFERENCE AND IMPACT ANALYSIS A mobile phone network consists of a system of adjoining zones called ‘cells’, which vary in size with a radius of 2 - 10 km. Each cell has its own base station that sends and receives radio signals throughout its specified zone. Mobile phone antennas need to be mounted clear of surrounding obstructions such as buildings to reduce ‘dead spots’ and allow the base station to effectively cover its intended cells. 21 Mobile phone coverage is available in much of the area around Glen Innes but is patchy further away from Glen Innes and the main highways and where topography limits coverage. During site investigations for the environmental assessment of the Glen Innes wind farm by Connell Wagner, mobile phone coverage was observed to be available for elevated locations on Waterloo Range and most areas between Waterloo Range and Glen Innes. However, coverage was absent or intermittent in the valleys to the west of the Glen Innes wind farm site. 22 Advice obtained from mobile phone service providers indicates that mobile phone services in these rural areas are mainly focussed on the main transport routes such as the New England and Gwydir Highways. In view of the separation distance between the base antennas and turbine structures and the wind farm location relative to areas of existing coverage, transmission of mobile phone signals may not be significantly affected by the operating wind farm. 23 21 URS Crookwell II Wind Farm Environmental Impact Statement , 22 Glen Innes Wind Farm Environmental Assessment – Telecommunications interference October 2008, Connell Wagner 23 ibid 16 Telecommunication/ and Electromagnetic Interference Impact Assessment – White Rock Wind Farm The ACMA RADCOM database identified three mobile phone companies as using base stations within the vicinity of the proposed wind farm. The table below lists the companies and ACMA site ID numbers. Mobile Phone Companies ACMA Site ID No. Optus Mobile Pty Ltd / Singtel Optus Pty Ltd 130216, 130217 Telstra Corporation Ltd 6905, 6910, 6948, 9007743 Vodafone Network Pty Ltd 6955, 130216 All companies were contacted by EPURON regarding potential impacts and asked to provide feedback as to any potential conflicts with their existing networks. No objections were received. 5.3 MITIGATION MEASURES No additional mitigation measures are required. 6 RADIO COMMUNICATION SERVICES 6.1 EXISTING SERVICES AND FACILITIES The ACMA issues radio communications licenses in accordance with Part 3.5 of the Commonwealth Radiocommunications Act 1992. The ACMA issues licenses to use specific segments of the radio broadcasting frequency spectrum for different purposes and maintains a register (the ACMA RADCOM Database) of all the licenses issued. The register allows the ACMA to create a ‘density’ classification of areas across Australia as high, medium or low depending on the number of licenses in operation in a particular area. According to the ACMA RADCOM database, the area in the vicinity of the proposed wind farm is classified as a “Low Density Area”. License holders operate a range of radio communications services, including fixed link microwave communication and mobile communication systems within a 25km radius of the proposed wind farm. Multiple license holders use some sites, while sole users employ others. Radio communications sites within a 25km radius are listed below. 17 Telecommunication/ and Electromagnetic Interference Impact Assessment – White Rock Wind Farm 18 Telecommunication/ and Electromagnetic Interference Impact Assessment – White Rock Wind Farm ACMA Licence Holder ACMA Site ID No. 2KY Broadcasters Pty Ltd 6955 Airservices Australia 6931 Ambulance Service of NSW 6909 Australian Broadcasting Corporation 6941, 6955 Church Communities Australia Ltd 9004089 Country Energy 6909, 6939, 6943, 35679 David E Jones 9009206 Deepwater Districts Community FM radio 34912 Dept of Environment Climate Change and Water 6837, 6898 Digital Distribution Australia 6910, 6948 Glen Innes and District Amateur Radio Club 250676 Glen Innes Radio Cabs 34912 Glen Innes Severn Council 34847 19 Telecommunication/ and Electromagnetic Interference Impact Assessment – White Rock Wind Farm ACMA Licence Holder ACMA Site ID No. Guyra Shire Council 6898 Guyra Volunteer Rescue Association 6898 Loanaoks Pty Ltd 280220 NBN Ltd 6955, 151348 Northern Broadcasters 35679 Northern River Television Pty Ltd 6898, 151348 Northern Tableland UHF users committee 6892 NSW Fire Brigades 6889, 34847 NSW Police Force 6909 NSW Rural Fire Service 6898, 34912 NSW State Emergency Service 51302, 250676, 9008678 NSW Volunteer Rescue Association 34847 Optus Mobile / Singtel Optus 130216, 130217 Origin Energy Holdings 280046 Prime Television (Northern) 151348 Radio 4GG Gold Coast Pty Ltd 136792 Roads & Traffic Authority 204416 Soul Pattinson Telecommunications 6863, 6948, 205033 Special Broadcasting Service Corporation 6955 St John Ambulance 306347 Sundown Pastoral Company 404373 Telstra 6905, 6910, 6948, 9007743 TransGrid 6909 Vertical Telecoms Pty Ltd 6898 Vodafone Australia Pty Ltd 6955, 130216 United Christian Broadcasters Australia Ltd 34847 Figure 9 - Radio communication license holders within 25km of the White Rock wind farm site 6.2 INTERFERENCE AND IMPACT ANALYSIS A fixed link microwave radio transmission is a point to point transmission path typically between two elevated topographical features. The transmission path may become compromised if a wind farm is located within the direct line of sight or what is known as the ‘Fresnel Zone’ around the line of sight between the sending and receiving antennae. The potential impact zone will vary with the distance between the transmitter and receiver, frequency of transmission and the location of any particular point along its path. Communications 20 Telecommunication/ and Electromagnetic Interference Impact Assessment – White Rock Wind Farm are only likely to be affected if a wind farm is in the line of sight between two sending and receiving antennae or within a zone of the line of sight of these antennae. Where a potential exists for interference to line of sight links, an obstruction analysis can be undertaken to ensure that no part of a wind turbine assembly will enter the Fresnel Zone of the microwave link. The maximum extent of the Fresnel zone occurs at the midpoint along the path of the microwave link. 6.3 RADIO COMMUNICATION LINKS EPURON identified and mapped all point to point communication links existing in the vicinity of the proposed wind farm site at the time of writing to establish the line of sight paths. Figure 10 provides details of the location of fixed microwave links crossing the site. (Based on data contained in the ACMA RADCOM database, April 2010.) 21 Telecommunication/ and Electromagnetic Interference Impact Assessment – White Rock Wind Farm Figure 10 - Point to point radio links in the vicinity of the White Rock wind farm site (original turbine layout) 22 Telecommunication/ and Electromagnetic Interference Impact Assessment – White Rock Wind Farm MAP_ID LINK_ID ACCESS_ID FREQUENCY CLIENT_NO 174412 1252330 42710000 12138 1 174412 1252329 44710000 12138 LICENSEE TransGrid TransGrid Length (m) 119100 119100 Figure 11 - Licensee list In order to ensure that obstruction to the signal transmission path does not occur; calculations of the 2nd Fresnel zone of the point to point communications link crossing the site were undertaken. It is suggested that beyond the 2nd Fresnel zone, the power of a scattered signal from a structure such as a wind turbine would be small enough such that it would not result in significant interference at the receiver. 24 . Completion of an obstruction analysis showed that a number of turbines were located within the 2nd Fresnel zone or close to the direct line of sight path of the point to point link crossing the site. Accordingly, Mr. Michael Freeburn from TransGrid, the corresponding link license holder, was notified and provided with details of the White Rock wind farm proposal for assessment on 10-810. At the time of writing, a response from TransGrid had not been received by EPURON. Research of recent literature suggests that interference to VHF links (i.e. in the 30MHz - 300MHz frequency range) by wind turbines is not likely. The TransGrid link crossing the site operates with a frequency of 42.7MHz and so falls within this range. Auswind best practice guidelines states: “The communications systems most likely to be affected (by wind turbines) are those which operate at super high frequencies (particularly microwave systems operating at frequencies above 300MHz)” Garrad Hassan’s “Assessment of Electromagnetic Issues for the proposed Berrybank Wind Farm”, insists that only frequencies greater than UHF range (300MHZ - 3GHz) may potentially experience interference from wind turbines. 25 The same view was also taken by Energreen Wind Pty Ltd in their Black Springs Wind Farm EMI assessment dated 26-7-2006: "UHF and VHF voice services have been found not to be affected by wind turbines unless the turbines are in the immediate vicinity of an antenna such that “near field” issues occur. The Blayney wind farm, south west of Sydney, NSW lies directly in the path of a VHF link and there has reportedly been no discernable interference as a result of the development." 26 Therefore, based on: ¾ The results of the above literature research, ¾ A high level, preliminary assessment and verbal advice from Garrad Hassan in relation to the TransGrid link (pers. comments Sherrin Yeo 20-8-10), ¾ The frequency of the link being in the low VHF range (30MHz - 300MHz) and ¾ The fact that the wind farm is not in the vicinity of an antenna, 24 D. F. Bacon, A Proposed Method for Establishing an Exclusion Zone around a Terrestrial Fixed Link outside of which a Wind Turbine will cause Negligible Degradation of the Radio Link, Radiocommunications Agency UK Report Ver 1.1, 28 Oct 2002 25http://www.unionfenosa.com.au/BB_Application_Report/BB_Appendix_9_Telecommunications_Assessment.pdf (page 3/23) 26http://majorprojects.planning.nsw.gov.au/files/1887/Appendix%20G%20Electromagnetic%20interference%20study.pdf 23 Telecommunication/ and Electromagnetic Interference Impact Assessment – White Rock Wind Farm Interference to the existing point to point communication link from the White Rock wind farm is not expected. EPURON previously contacted all organisations identified as operating radio communication licences (including fixed link communications) within 25km of the Cullerin Range wind farm proposal, which is now operational and without communications issues in the area. Each license holder was asked to provide independent comment on the wind farm development with respect to possible impacts to communication links. At that time, no organisation within the 25km radius raised concerns. Optus, Vodafone and Telstra provided general guidelines to assist in the planning of wind farm. In response to these enquiries, the following comments were noted, "Provided wind turbines are located well outside the 2nd Fresnel zone of the point to point microwave links, no interference to communications is expected" (pers. comm. Mr. Trong Ho, Optus Mobile) 27 “Clearance criteria is the same for all carriers. Please use the same criteria as proposed by Optus” (pers. comm. Mr. Ganesh Ganeswaran, Senior Engineer / Transmission, AAP Communications Services 22/11/05) 28 “Provided wind turbines are greater than 100m away from Mobile tower (or in the case of directional panel antennae) not in direct line of sight for panel antennas, wind turbines will have minimal effect on existing coverage.” (pers. comm. Mr. Ivan D’Amico, Area Team Manager (Country) - NSW&ACT, Telstra Services, Wireless Access Solutions, Mobile Coverage Delivery) 29 The above suggestions have been considered in the planning of the White Rock wind farm proposal. 6.4 OTHER RADIO COMMUNICATION 6.4.1 Two way mobile A small number of mobile bases exist in the area surrounding the wind farm site. These bases potentially provide cover to mobiles in a 360 degree arc from their bases. No significant impact from the wind farm on base coverage beyond normal mobile operational performance is predicted in view of the geographic separation between the base antennas and the turbine structures. Of course a mobile unit communicating with a base station when the mobile is located within metres of the wind turbine structures (or indeed near any large building, silo, tower etc) may experience some very local performance change, however moving a short distance would restore performance to normal. 30 6.4.2 CB radio CB radios are not individually licensed, the equipment being subject to class licensing only. Therefore, no records of location or operators of CB radios exist, and the channels are shared without any right of protection from interference. No impact from the wind farm is predicted 27 Taurus Energy - Cullerin Range Wind Farm Environmental Assessment Report 2006 28 Ibid. 29 Ibid. 30 Lawrence Derrick & Associates Bannister Wind Farm – Investigation of possible impacts on broadcasting and Radio communication Services September 2003 24 Telecommunication/ and Electromagnetic Interference Impact Assessment – White Rock Wind Farm except perhaps for very local effects to portable or mobile units in the immediate vicinity of the turbines which could be avoided by a small location change of the unit. 31 6.4.3 Wireless broadband From studies in other areas such as Mahinerangi, NZ 32 it is concluded that the minimum separation required between wind turbines and mobile broadband transmitters is approximately 240m. Turbines will be located outside this distance to avoid any impacts on mobile broadband services where possible. 6.5 MITIGATION MEASURES As a result of the exclusion zones established in planning the wind farm, the possibility of impacts to existing point to point communication links is reduced. However, in the unlikely event that interference is observed, the proponent is confident that impacts will be able to be mitigated using the following techniques: 7 ¾ Modifications to or relocation of the existing antennae ¾ Installation of a directional antennae to reroute the existing signal ¾ Installation of an amplifier to boost the signal and/or ¾ Utilisation of onsite optical cable to reroute the original signal. ELECTRIC AND MAGNETIC FIELDS 7.1 WHAT ARE ELECTRIC AND MAGNETIC FIELDS? The existence of electric and magnetic fields (EMFs) has been recognised since electricity was discovered, and their characteristics have been the subject of thousands of scientific studies around the world. Research conducted over the past 25 years has significantly enhanced our knowledge of EMFs. Electric fields are produced every time a voltage exists across a conductor. The higher the voltage, the stronger the electric field. Electric fields are strongest closest to the conductor and their level reduces quickly with distance. Most materials act as a shield or barrier to electric fields. The level of electric fields is measured in thousands of volts per metre (kV/m). Magnetic fields are produced by the flow of an electric current through a conductor. The higher the current, the greater the magnetic field. The strength of magnetic fields is measured in milliGauss (mG). Like electric fields, magnetic fields are highest closest to the conductor and their level reduces quickly with distance. Most materials will not act as a shield or barrier to magnetic fields. 7.2 WHEN DO ELECTRIC AND MAGNETIC FIELDS OCCUR? Electric and magnetic fields (EMFs) occur both naturally and from man made sources and are not unique to high voltage power lines. 31 Ibid. 32 Mahinerangi Wind Farm Compatibility with radio services April 2007 - Kordia 25 Telecommunication/ and Electromagnetic Interference Impact Assessment – White Rock Wind Farm Natural EMFs are associated with such things as lightning, solar activity or the earth’s magnetic field. All living organisms, including humans, have natural electric charges, currents, electric and magnetic fields. Man made EMFs occur whenever electricity is being used in any form of electrical equipment or wiring. Most people will be exposed to a wide variety of EMF sources throughout their daily lives. As electricity use is so widespread in modern society, questions about its possible effects on health are important to everyone. Biological and occupational health research on EMFs began in the early 1960s. Since that time many national and international review panels, such as the World Health Organisation, the US National Institute of Environmental and Health Sciences and the UK National Radiological Protection Board have evaluated the research to assess the likelihood of health effects being associated with exposure to electric and magnetic fields. In Australia, the relevant health authority is the Australian Radiation Protection and Nuclear Safety Agency (ARPANSA), an arm of the Commonwealth Department of Health. In response to a recent report, the CEO of this agency said: “It is also important not to fixate on the location of external power lines, including high voltage transmission lines, as the prime cause of exposure. Exposure to ELF magnetic fields can arise from ground currents, internal household wiring and the use of electrical appliances as much as from exposure to external powerlines.” Government Agencies such as ARPANSA have also monitored international research on the topic, concluding that, “On balance, the scientific evidence does not indicate that exposure to EMF’s found around the home, the office or near power lines is a hazard to human health” 33 7.3 WHAT ARE THE ELECTROMAGNETIC FIELD IMPLICATIONS OF WIND FARMING? There are four potential sources of EMF associated with wind farming. These are: ¾ ¾ ¾ ¾ The grid interconnection power line The wind turbine generators Any electrical transformers The underground collector network cabling The interconnection with the existing grid is usually made above ground and is no different from any other power line used in the network. The EMF levels are comparable to typical household appliances i.e. negligible. The electrical generator windings are close together and surrounded by conductive metal housing so the electromagnetic fields are effectively zero. 33 http://www.transgrid.com.au/she/swp/Documents/EMF%20Brochure.pdf 26 Telecommunication/ and Electromagnetic Interference Impact Assessment – White Rock Wind Farm The switchyard transformer, which will carry the entire output of the wind farm, is generally located in the central part of the switchyard and the protective fencing means it is not possible for members of the public to come close enough to be exposed to appreciable EMF. The collector network, which connects the various turbine generators of a wind farm operates at typical distribution voltages and is buried at least 750mm below ground level. Because of the closeness of the phase conductors within the cables and the screening of the cables, the electromagnetic fields are balanced out to be effectively zero. The electromagnetic fields associated with generation and export of electricity from a wind farm does not pose a significant threat to public health. Consequently, no serious or adverse EMF or interference issues are anticipated from a wind farm. 34 7.4 MITIGATION MEASURES No mitigation measures are required. 8 CONCLUSION Conflicts between point to point radio systems and the wind turbines are not expected. Also, mobile radio and other radio communication services in the area are not expected to be impacted by the wind farm or its operation. Analogue TV transmission is currently planned to be phased out by 2013 and replaced by digital. Digital TV is not susceptible to visible “ghosting” degradation. Any impact of reflections from the turbines would be a minor reduction of coverage at the limit of the service area. For any confirmed wind farm interference problems where TV antenna system improvements are unsuccessful, the use of the digital TV services in the area may be the best solution, requiring the provision of a digital set top converter. Interference to MF and FM sound broadcasting is not expected. Overseas experience indicates that electrical interference from wind farm generators and controls is not a problem with established and reputable wind turbine manufacturers and therefore no electrical noise measurements are warranted. Obstacle lighting is not expected to be a requirement at this site. A detailed site assessment of the most sensible option in relation crop dusting and top dressing would need to be made by the involved landowner and the proponent with the advice of appropriately licensed contractors once the project has been completed. 9 TURBINE CO-ORDINATES WTG_ID WRK_002 WRK_003 WRK_004 Easting 367453.73 367103.67 367115.43 Northing 6693821.45 6697103.65 6697506.42 WTG_ID WRK_065 WRK_066 WRK_067 34 http://www.wind.appstate.edu/reports/BP10_EMC&EMF.pdf 27 Easting 360165.8 360061.4 361694.9 Northing 6698737 6699431 6703606 Telecommunication/ and Electromagnetic Interference Impact Assessment – White Rock Wind Farm WRK_005 WRK_006 WRK_007 WRK_008 WRK_009 WRK_010 WRK_011 WRK_012 WRK_013 WRK_014 WRK_015 WRK_016 WRK_017 WRK_018 WRK_019 WRK_020 WRK_021 WRK_022 WRK_023 WRK_024 WRK_025 WRK_027 WRK_028 WRK_029 WRK_030 WRK_031 WRK_032 WRK_033 WRK_034 WRK_035 WRK_036 WRK_037 WRK_038 WRK_039 WRK_040 WRK_041 WRK_042 WRK_043 WRK_044 WRK_046 WRK_047 WRK_048 WRK_049 WRK_050 WRK_051 WRK_053 WRK_054 WRK_055 366016.9 365568.24 365617.81 365710.01 366143.71 365149.51 364716.4 361627.81 361818.4 366558.27 366869.1 363005.3 363030.1 364654.6 362954.21 362879.61 362828.5 364715 364727.11 363365.51 362981.91 362597.41 362373.01 362545.59 362644.8 362612.4 362412.8 362470.02 362560.7 362184.94 362238.02 362002.83 362176.39 361547.85 361525.05 361551.85 361753.6 361382.31 361427.83 361404.69 361291.1 361030.87 361311.31 361440.1 361422.49 361319.96 360956.11 361201.76 6694075.5 6694818.52 6694558 6694282.5 6693813.49 6695285 6695348 6698554.44 6698224.5 6698404.99 6698144.49 6695983.5 6695660.5 6695615.5 6696286.5 6696840.5 6696559.5 6696372 6696087.5 6694909 6695387 6690520.99 6690279.49 6697147.06 6697511.26 6697809.5 6698644.5 6698378.16 6698099.84 6695344.47 6695084.85 6697628.33 6697368.52 6699356.53 6699085.42 6698813.93 6692602.92 6692764.5 6696617.21 6696366.07 6691510.49 6691290.99 6691034.5 6695212.5 6695759.05 6696045.64 6697318.42 6697069.21 WRK_068 WRK_069 WRK_070 WRK_071 WRK_072 WRK_073 WRK_074 WRK_075 WRK_076 WRK_077 WRK_078 WRK_080 WRK_081 WRK_082 WRK_083 WRK_084 WRK_085 WRK_086 WRK_087 WRK_089 WRK_090 WRK_091 WRK_092 WRK_093 WRK_094 WRK_095 WRK_096 WRK_097 WRK_098 WRK_099 WRK_100 WRK_101 WRK_102 WRK_103 WRK_104 WRK_105 WRK_106 WRK_107 WRK_108 WRK_109 WRK_110 WRK_111 WRK_112 WRK_114 WRK_115 WRK_116 WRK_117 WRK_118 28 361718 361686.4 361725.1 361645.2 361545.3 361127 361423.4 361205.9 361286.8 361250.5 360319.3 359908.5 360345.4 360235.7 359905.8 359992.8 359907.6 359863.1 359898.7 360166.3 359600.1 359685.8 359665.2 359663.8 359658 359246.8 359202.9 359169.5 359422.4 359468.8 359176.4 359252.7 359455.5 359376.9 359186.2 359242.5 362683.3 359210.1 359852.6 359023.6 361431.3 362968.9 366959.2 367053.1 366767.4 365255.7 364364.6 362014.9 6703255 6702678 6702938 6702414 6702150 6701687 6701163 6700913 6701426 6703057 6702379 6701419 6702053 6701775 6700772 6701137 6700489 6699736 6700199 6702721 6703621 6703353 6704433 6704162 6703876 6704867 6702484 6702205 6701317 6700831 6701055 6701580 6700147 6705707 6705126 6704577 6690796 6705405 6703104 6701878 6695495 6695085 6693853 6698762 6696860 6695022 6695828 6697924 Telecommunication/ and Electromagnetic Interference Impact Assessment – White Rock Wind Farm WRK_056 WRK_057 WRK_058 WRK_059 WRK_060 WRK_061 WRK_062 WRK_063 WRK_064 360825.43 360436.61 360405.3 360809.61 360248.1 360512.86 360200.51 359822.21 360174.81 6697676.98 6693254 6692983.5 6692793.5 6698186.99 6697920.1 6698467.5 6699192.5 6699010 WRK_119 WRK_120 WRK_122 WRK_123 WRK_124 WRK_125 WRK_135 WRK_136 366975.6 360404.6 364441.9 364626.5 364458.6 368091.1 359318.8 358792.3 6698466 6701025 6697003 6696645 6697276 6696553 6699188 6699215 10 FRESNEL ZONE CALCULATION Link ID 174412 - Licence 1251917 Link length 119100m d1 (m) 0 10000 20000 30000 40000 50000 60000 70000 80000 90000 100000 110000 119100 d2 (m) 119100 109100 99100 89100 79100 69100 59100 49100 39100 29100 19100 9100 0 Frequency (MHz) 42.7 42.7 42.7 42.7 42.7 42.7 42.7 42.7 42.7 42.7 42.7 42.7 42.7 29 Fresnel Zone (2nd) metres 0 358.7717031 483.5680871 561.5717939 610.9758501 638.4543243 646.8076869 636.7890297 607.4900641 555.8704097 474.7035621 343.6551413 0 Telecommunication/ and Electromagnetic Interference Impact Assessment – White Rock Wind Farm 11 CORRESPONDENCE From: SULLIVAN, BYRON [mailto:BYRON.SULLIVAN@casa.gov.au] Sent: Tuesday, 17 August 2010 8:38 AM To: Anthony Micallef Subject: White Rock Wind Farm near Glen Innes NSW. [SEC=UNCLASSIFIED] Anthony, Thank you for your e-mail and attached letter dated 13 August 2010. 2. At this time, CASA has no specific authority to direct action relating to structures, including Wind Farms, located away from aerodromes. You should undertake the following consultation to assess the potential hazard posed to aviation by the proposed development. 2.1. Identify any aerodrome within 30 km of the boundaries of the proposed wind farm and consult with the aerodrome operator to determine any impact on Obstacle Limitation Surfaces at such aerodromes. Penetration of these surfaces is likely to pose a hazard to normal aviation operations at the aerodrome. 2.2. Consult with Airservices Australia (02 6268 4111 - Ms Michelle Bennetts) to have them assess any potential impact on instrument approach procedures at aerodromes, navigational aids, communications facilities or surveillance facilities. 2.3. Contact the Aerial Agriculture Association of Australia (02 6241 2100 - Mr Phil Hurst) to advise him of the proposal and gain comment on the potential hazards to aerial application and related operations in the area. 3. You advise that the maximum height reached by the turbine blades is likely to be up to 150 m. Aircraft are permitted to fly as low as 500 ft, which is equivalent to 152 m. This being only 2 m above the height reached by the proposed turbine blades, and allowing for probable tolerances in aircraft altitude, the proposed turbines are likely to be a hazard to aircraft traversing the area. It is recommended that you consider your duty of care in deciding whether or not the wind farm should be obstacle lit or other wise marked. 4. The location, extent and height of the wind farm is to be advised to: Aeronautical Data Officer RAAF AIS (VBM-M2) Victoria Barracks St Kilda Road, Southbank, VIC, 3006 E-mail: ais.charting@defence.gov.au Thank you for your interest in Aviation Safety. Byron N SULLIVAN. Aerodrome Engineer - (Aerodrome Lighting) Airways and Aerodromes Branch From: TRIPCONY, Bill [mailto:BTripcony@ambulance.nsw.gov.au] Sent: Thursday, 19 August 2010 11:27 AM To: Anthony Micallef Subject: RE: White Rock Wind Farm - Ambulance Service of NSW Anthony, The wind farm as proposed will not interfere with Ambulance Service radio communications. Bill Tripcony Telecommunications Manager 9320 7830 30 Telecommunication/ and Electromagnetic Interference Impact Assessment – White Rock Wind Farm -----Original Message----From: Greg Williams [mailto:gwilliams@nbntv.com.au] Sent: Friday, 20 August 2010 1:26 PM To: Anthony Micallef Cc: ghird@nbntv.com.au Subject: Emailing: Dowe to Glen Innes Path.pdf Hi Anthony, Thank you for contacting us in regards to the proposed White Rock wind farm. As we discussed, we are concerned that there will be significant impact on the television reception in Glen Innes. The translator site at Carpenters Hill receives its input signal from the parent site at Mt Dowe (ACMA site ID 35653). As shown in the attached pdf it passes through the area proposed for the wind farm. While our CSIRO data is based on scattering interference caused by wind turbines much closer than 25km I believe that you need to take this possible interfernce into account as it has the potential to disrupt commercial television reception to the whole town of Glen Innes, not just individual viewers. We need to identify these issues before any construction starts because the remedy, if required, will take several months to implement. The broadcasters concerned are NBN, Southern Cross Broadcasting (Macquarie Southern Cross Media) and Prime. Regards, Greg Greg Williams Broadcast Engineering Manager NBN Television 11 - 17 Mosbri Cres Newcastle 2300 02 4929 2933 0428 503 678 gwilliams@nbntv.com.au From: HONG John [mailto:John_HONG@rta.nsw.gov.au] Sent: Monday, 23 August 2010 5:48 PM To: Anthony Micallef Cc: COOK Ron (IM&IT) Subject: RE: White Rock Wind Farm - Roads and Traffic Authority Anthony, I have no concern of your proposed wind farm project, as this would generate insignificant noise impacts to the RTA radio communication services in the Glen Innes vicinity. Regards John Hong Radio System Manager Transport Management Centre 25 garden St, Eveleigh NSW 2015 tel: 83961626 From: Jayantha Wickramasinghe [mailto:Jayantha.Wickramasinghe@optus.com.au] Sent: Tuesday, 24 August 2010 9:53 AM To: Anthony Micallef Cc: Trong Ho; Maxi Victoria Subject: RE: White Rock Wind Farm - Singtel Optus Dear Anthony 31 Telecommunication/ and Electromagnetic Interference Impact Assessment – White Rock Wind Farm The proposed White Rock wind farm development has no impact on existing or planned Optus network infrastructure. Regards Jayantha From: David Boundy [mailto:david.superair@iinet.net.au] Sent: Tuesday, 24 August 2010 10:23 AM To: Anthony Micallef Cc: 'Carol @ Superair' Subject: WIND TURBINES Anthony hi, Following is a response to the letter dated 16 August 2010 from you in relation to the proposed White Rock Wind farm. There are 2two letters, one from us putting our position forward and one that was submitted by the Aerial Agricultural Association of Australia to the General Purpose Standing Committee which is still relevant. If you have any questions of either response please don’t hesitate to call. Regards David 24-08-2010 EPURON Level 11, 75 Miller st North Sydney,NSW,2060 Ph 02 8456 7400 Fax 02 9922 6645 Attention;- Anthony Micallef Dear Anthony 32 Telecommunication/ and Electromagnetic Interference Impact Assessment – White Rock Wind Farm Superair Australia’s position on the proposed wind farm is that we “OBJECT”, unless measures are put into place to allay our concerns regarding what we feel could be negative impacts on our business. Firstly some background, I am presently the manager of Superair Australia which was established in 1964 in Armidale. Since then we have grown to become the largest aerial topdressing company in Australia. We have bases in Glen Innes, Armidale, Tamworth, and Scone. We employ 22 local staff which comprises aircraft engineers, commercial pilots, truck drivers and administration persons. We operate a fleet of over 10 aircraft and loader trucks. These wind farms will become a huge obstacle in performing our main occupation as an aerial topdressing company. These wind turbine structures are approximately 110 metres above ground level. As you may or may not be aware we carry out our flying operations between 20-30 metres above ground. The problems that we face would be quite apparent from these figures. We have a hard time coming to grips with the fact that these towers will decrease our safety margins, which may ultimately lead to a negative effect on our turnover. This could contribute to a loss in local jobs. I hope I am proven to be wrong. Until the towers are in place we do not know from a safety aspect or quality of work that if in fact we will be able to continue aerial fertilizing in these areas as we have done for the previous 44 years. The Ben Lomond and Glen Innes area contribute a large amount of monies to our turnover and to lose this through no fault of our own is going to make it a lot harder for survival in a high overhead profession and business that we operate. There are other wind farms in Australia and aerial agricultural operations take place near them. The problem is that these wind towers are erected in a totally different topographical location, be it, altitude, topography, local wind strength, local wind shear, dwellings, airstrip locations, and several other factors dictate the ability to carry out low level aerial operations safely and cost effectively. Therefore each proposed wind farm has to be treated on a case by case basis and not just from an overall view of how interested parties such as the aerial agricultural industry are considered in the overall planning and assessment of the proposal. I have had meetings with the developers of the wind farms, mostly positive at the time. What I find frustrating is that each couple of years the developers seem to change through company restructuring or takeovers from another company. Any agreement we may have had seems to fall by the wayside and we start over again from the beginning. Also I am not sure how legally binding any agreement is between the parties. The following is an extract from previous correspondence that I have sent to our aerial fertilizer clients that will be affected by having wind turbines erected on their properties or adjoining landholders that are affected as well. It explains in some detail the problems that we will and may encounter once the wind turbines are erected. As I have said before, we can not foresee all problems that may be encountered with something that you can not see at the present moment and have to try and visualise, as well as all the variables that we try to deal with in our present operation, being mainly the weather & terrain. What I can say though, and this is definite, is that these wind turbines will – (this applies to both the property with the towers as well as the adjoining properties without towers) Decrease our safety Decrease our productivity Decrease accuracy of the fertiliser deposits Decrease productivity of the pastures to the landholder Increase costs to the landholder Decrease our revenue I will try to expand on the points I have raised – Decreased Safety – the average height that we fly to aerial top dress pastures is between 20-30metres. These towers are in the vicinity of 110 metres in height. Therefore the safety aspect is self explanatory. Decreased productivity – when we carry out the aerial operation we attempt to fly a grid pattern in straight lines. The flight lines, directions & spacings, are influenced by the a) b) c) d) e) Safe operation of aircraft Topography Layout of the property or the section being treated Co-efficient of variation of the deposition pattern Weather conditions existing at the time If any or all of the factors influence too heavy on safety or productivity, we may not be able to carry out the aerial topdressing at all. A set of towers will effectively change the topography. They will also change our line directions causing a decrease in productivity (eg. Shorter runs, more turns). To enable productivity to be as high as possible we carry as much pay load as is safe to do so. If we have to climb an extra 100 metres or greater, our pay load will have to be decreased, therefore causing a decrease in productivity. This cost would have to be borne by the landowner in increased charges. One major factor that would not be measurable until the towers are in place is the turbulence generated by the structures. If this 33 Telecommunication/ and Electromagnetic Interference Impact Assessment – White Rock Wind Farm was too great, the operation may have to cease. Another decrease in productivity, whereas before it would have not been a problem. Decreased accuracy of fertiliser deposits – commonly referred to as co-efficient of variation. We as pilots fly anywhere between 20-30 meters depending on several factors – safety, topography, size of treatment area & shape of treatment area. If we have to fly at 110 metres or greater, we can not accurately determine or would not give guarantees as to the accuracy of fertiliser deposits on to the property, or that we would even maintain them within the boundaries at all times. I would feel that there would be areas that we could not treat at all. Decreased productivity to the landowners – because of the accuracy being compromised and sections of land not being able to be treated properly, the growth rate of pastures would be effected, therefore decreasing productivity on that property Increased cost to landholders – there will be an increased cost to landholders because of the explained above. This could be anywhere from $5 per hectare, bearing in mind if we are able to do the job at all. Decreased Revenue – what I can see but hope it would not happen is that because of our decreased accuracy, some of our landholders may look to get fertiliser applied by different means eg. Ground spreading. This means our income would be directly affected and properties that we have traditionally done for many years we would lose to alternative application methods. These towers are a massive obstacle to our operation. We, as agricultural topdressing pilots, already have a high concentration level with the associated risks that we presently deal with. These towers will add another dimension to our occupation, which I can honestly say we would not welcome for obvious reasons. . I am only too happy to offer an insight into our operations and complexities that do not exist in another form of commercial flying operations in the world. I would offer to take anyone interested for a simulated topdressing flight in our aircraft at a time & place convenient to both parties. It may be only then that a somewhat minor understanding of what our occupation entails would be achieved by the developers of these wind turbines, and then they may realise the adverse effects on our business. “If the following suggestions could be agreed too with developers before construction occurs, then it would go a long way to alleviating our concerns about the whole wind farm development in our operational areas.” Increased flying time & costs Where a surcharge for additional flying time for aerial operations is incurred by a landowner with wind turbines located on his/her land due to the presence of those turbines, the developer shall meet the full cost of this surcharge. This may include adjoining properties with not wind turbines on that land, but proximity of the turbines causes flight path changes to complete aerial operations The surcharge shall be calculated by the aerial operation as a fair charge for additional flying time. The developer or the controlling body shall pay the surcharge directly to the aerial operator upon receipt of an invoice and sufficient information to justify the surcharge. It is believed that a fair surcharge rate per hectare per property, independent of weather conditions, could be negotiated in Year 1 & 2 and applied to each subsequent aerial operation to save detailed cost justification of every operation on each property. This agreement would have to last the natural life of the wind turbines. Decreased accuracy of fertiliser spreading It is understood that a decrease in fertiliser spreading accuracy is likely to only occur over a proportion of the properties being considered for wind farm development, depending upon the configuration and proximity of turbines. Specifically fertiliser spreading accuracy along property boundaries appears to be the most critical issue, avoiding fertiliser application on the neighbours land. In response to this, the following is proposed: An additional 5-10% of fertiliser by volume will be purchased by the developer or controlling body for each fertiliser spreading operation on each property that is likely to incur spreading inaccuracy along a property boundary or adjoining property boundaries. With the additional flying time incurred to spread this additional amount of fertiliser, the associated cost will be met by the developer or controlling body. Those properties where spreading inaccuracy is likely to occur along a boundary will be identified in the first application of Aerial operations after the turbines are in place. This agreement would have to last the natural life of the wind turbines. Decreased Revenue If we were to lose traditional customers to alternative means of fertiliser application, eg:-( ground spreading operations). We would like to see a clause in the development consent or approval that, “ IF ANY PARTIES ARE ADVERSLY AFFECTED AND MAY LOOSE REVENUE THROUGH CONSTUCTION OF A WIND FARM, EVEN THOUGH 34 Telecommunication/ and Electromagnetic Interference Impact Assessment – White Rock Wind Farm THEY MAY NOT BE THE LAND OWNER,THAT THERE A PROCESS OR AGREEMENT DOCUMENTED FOR COMPENSATION TO THESE BUSINESSES.”. This would have to last the natural life of the wind turbines. To sum up, I can see our business being adversely affected through no fault of our own by these wind turbines. All I am asking for is a fair outcome for us or any other parties that may be affected as well. I can be contacted on any of the numbers listed at any time if there are any questions that anyone may have. If we all communicate and address the problems that we have raised I can only see positives coming out of these types of developments. Kind regards David Boundy. Manager Superair Australia AERIALAGRICULTURAL ASSOCIATIONOFAUSTRALIA LTD. ABN 13 002 501 886 • ACN 002 501 886 21 August 2009 The Director General Purpose Standing Committee Number 5 Parliament House Macquarie Street Sydney NSW 2000 By email: gpscno@parliament.nsw.gov.au Dear Director AAAA Submission to Inquiry into Rural Windfarms The Aerial Agricultural Association of Australia (AAAA) represents Australia’s aerial application industry, including crop protection spraying, fertilizer application and firebombing. Aerial application is heavily regulated by the Civil Aviation Safety Authority and pilots and operators are licenced to at least Commercial Pilots Licence standard and undergo ongoing professional development conducted by AAAA. AAAA works closely with CASA and industry members on safety promotion, training, regulatory development and identifying emerging threats to aviation safety and appropriate responses. A key emerging threat to aviation safety both in Australia and overseas is developing windfarm infrastructure. In particular, wind monitoring towers are a critical threat to low level aviation safety. There are two quite distinct issues arising from windfarms that affect aerial application: • safety of the aircraft and pilot and • economic impact on aerial applicators. Safety Impacts AAAA view is that the case of Sheather v Country Energy (NSW Court of Appeal) clearly established that anyone with infrastructure posing a threat to aviation must consider the risks that infrastructure poses to aviation safety and respond appropriately through marking or 2 other measures to safeguard aviation operations. This precedent is of critical relevance to windfarm developers. There are also a range of activities currently underway that are important to the consideration of the impact of windfarms and potential directions for the future. These include: • Commonwealth’s Aviation White Paper (Department of Infrastructure etc) • Commonwealth Inquiry into Safeguards for Airports and the communities around them (Department of Infrastructure etc) • CASA consultancy on safety implications of tall structures not in the vicinity of airports • Relatively recent review and release of the Australian Standard AS3891 - Air Navigation - Cables and their supporting structures Marking and safety requirements AAAA has made submissions to each of these processes and has consistently raised the need for appropriate risk management of windfarms and wind monitoring towers in an aviation context. For example, the AAAA submission to the Commonwealth Government’s Aviation White paper included the following recommendation: • Establish and fund a national database of powerlines, wind monitoring and power generation towers and other obstacles so as to address this significant threat to lowlevel aviation. Despite the best efforts of AAAA, such information is not made available from any power companies and most wind farm developers. 35 Telecommunication/ and Electromagnetic Interference Impact Assessment – White Rock Wind Farm This proposal is expanded on in the attached recent submission to the Commonwealth Government on Safeguards for Airports which is at Attachment A. AAAA has done a lot of work to make it easier to mark guy wires and powerlines – including on wind monitoring towers – through amendment of the national standard on marking of ires so as to use a new marker developed by Country Energy with the cooperation of AAAA. There is now little practical reason why wind towers and especially wind monitoring towers should not to be marked at least. In addition, AAAA has attempted to provide relevant information to any developer through the Wind Energy Association, but this process is voluntary and consequently will not provide coverage of all developers. AAAA also passes on information to members that has been provided to it by wind farm developers on the physical location of wind monitoring towers. However, only a few developers provide this information and again there is little doubt that many towers are going up unmarked and unknown until hopefully spotted by pilots during pre-application inspections. More comprehensive safeguards must include a national system of communication the position of all wind monitoring towers and the inclusion of this on a national database accessible by low level pilots. This is a very real issue for topdressing and firebombing operations, as wind monitoring increases, so does the threat to legal aviation activities. Economic Impacts Safety is not the only consideration that is imposing additional risk and consequences on the aerial application industry. The placement of wind farms in areas of highly productive agricultural land is leading to reductions in treatment areas of aerial application companies with no compensation for this externalization of costs by wind farm developers. For example, placement of a wind farm may affect flight lines and application height or even whether the application can be conducted at all - leading directly to either an increase in cost or a reduction in income - and sometimes both - for aerial application operators. AAAA’s submission to the Commonwealth Inquiry into Safeguards at Airports (Attachment A) makes a number of points regarding land planning issues that are equally relevant to the development of wind farms regardless of whether they are near airports or in agricultural land that may be treated by air. In particular, AAAA is concerned that not enough consideration is being given through the State planning processes to the impacts of windfarms on productive agricultural land and the aerial application industry, remembering that it may not only be the land footprint where the windfarm is sited, but also land surrounding that for some kilometers where aircraft may have to maneuver to conduct aerial application. At the very least, windfarm developers should be required to pay compensation to aerial applicators where it can be reasonable established that there will be an economic impact imposed on the aerial application company by the wind farm developer. Further information If you require any further information or would like AAAA to expand on or further explain any of the issues raised in this submission, please do not hesitate to contact the Association’s CEO, Mr Phil Hurst on 02 6241 2100 or email: phil@aerialag.com.au Yours sincerely Phil Hurst CEO - AAAA David Boundy Superair PO Box 76 Armidale NSW 2350 Australia superair@iinet.net.au Ph 02 6772 5055 Fax 02 6772 5931 From: Britto Tam [mailto:tam1bri@police.nsw.gov.au] Sent: Wednesday, 25 August 2010 12:45 PM To: Anthony Micallef 36 Telecommunication/ and Electromagnetic Interference Impact Assessment – White Rock Wind Farm Cc: Palitha Kuruppuarachchi Subject: [Update] Fw: Radio Impact Assessment for proposed White Rock wind Farm site and NSW Police services Hi Anthony, NSW Police Force would like to inform you that, after conducting radio impact assessment on its licensed radio services at ACMA site ID #6909 - Pacific Grid Site Trig Point Ben Lomond, the proposed White Rock wind farm location (with coordinates and boundary as indicated in your email dated 23-August-2010) would not affect our (NSW Police Radiocommunications) services. Kind Regards, Britto Tam NSW Police Force Tel: 02-9265-4702 Fax: 02-9285-3710 Email: tam1bri@police.nsw.gov.au From: Stephen Carter [mailto:fas@stjohn.org.au] Sent: Monday, 6 September 2010 11:11 AM To: Anthony Micallef Subject: Proposed White Rock Wind Farm Hello Anthony, In reply to you letter dated 16 August 2010 regarding the proposed White Rock wind farm and its potential impact on site 306347 (Wilson Park, Taylor Street, Glen Innes). My apologies for the tardy reply – one of the people I needed to consult with has been unavailable over the last couple of weeks. We do not believe that the proposed wind farm development will have an adverse impact on this site for the purposes of St John Ambulance Australia. Please do not hesitate to contact me if you require additional information and/or clarification. Cheers, Stephen 37 Telecommunication/ and Electromagnetic Interference Impact Assessment – White Rock Wind Farm 38 Telecommunication/ and Electromagnetic Interference Impact Assessment – White Rock Wind Farm LIST OF FIGURES FIGURE 1 - WHITE ROCK WIND FARM SITE LOCALITY FIGURE 2 - “FREE TO AIR” TELEVISION BROADCAST SERVICES AVAILABLE AROUND THE WIND FARM FACILITY FIGURE 3 - SCHEMATIC DIAGRAM OF POTENTIAL ANALOGUE TELEVISION SIGNAL INTERFERENCE ZONES AROUND A WIND TURBINE FIGURE 4 - HOUSES WITHIN 5KM OF THE WHITE ROCK WIND FARM SITE FIGURE 5 - TELSTRA 3G AND GSM COVERAGE FIGURE 6 - TELSTRA NEXT G NETWORK COVERAGE FIGURE 7 - VODAFONE GSM NETWORK COVERAGE FIGURE 8 - OPTUS GSM (3G) COVERAGE FIGURE 9 - RADIO COMMUNICATION LICENSE HOLDERS WITHIN 25KM OF THE WHITE ROCK WIND FARM SITE FIGURE 10 - POINT TO POINT RADIO LINKS IN THE VICINITY OF THE WHITE ROCK WIND FARM SITE (ORIGINAL TURBINE LAYOUT) FIGURE 11 - LICENSEE LIST 39 5 9 10 12 14 15 15 16 20 22 23