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BM comes out swinging on CASA's ineptitude on Tallawara B -   

Via Oz Flying:

 

CASA comes under Fire over Power Station Approval
14 April 2020
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The Civil Aviation Safety Authority has drawn criticism from AOPA Australia for approving an aviation impact assessment for the proposed Tallawarra B power station.


Last week, Energy Australia was granted planning approval for an open cycle gas turbine power station to be built in the circuit area of Shellharbour Airport after CASA accepted a gas plume velocity of 6.1 m/s at 700 feet as being safe.

Previously, AOPA Australia had calculated that a plume velocity of only 4.3 m/s would be needed to ensure the plume presented no danger to GA and recreational aircraft.

"AOPA Australia are deeply concerned that CASA have created a risk to the safety of aviation at Shellharbour Airport by their prime decision that a 6.1 m/s plume velocity at 700 feet AGL is an acceptable safety yardstick for the Tallawarra B project," AOPA CEO Ben Morgan said in a letter addressed to CASA CEO and Director of Aviation Safety Shane Carmody.

"AOPA Australia have presented CASA [with] calculations, using approved data from the Pilot Operating Handbook of the ubiquitous Cessna 172N, that show 4.3 m/s is the maximum critical plume velocity for any such assessment related to any plume within the circuit at Shellharbour Airport.

"Would you please explain how CASA concluded that a plume with a velocity of 6.1 m/s at 700 feet AGL within the circuit at Shellharbour Airport does not pose a risk to the safety of aviation?"

Morgan crticised CASA for approving the gas plume velocity based on what it says is a potential design and not the final design for the power station. Energy Australia put forward an engineering solution in the aviation impact assessment that was designed specifically to reduce the plume velocity.

Morgan said that AOPA was disappointed that CASA reviewed the assessment "behind closed doors, ignoring the input of the aviation community" and accused the regulator of then "wiping its hands" of the outcome.
Energy Australia plans to commission Tallawarra B in the summer of 2022-23.

Dear Mick Mack - L&Ks BM 

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 AOPA AUSTRALIA | CASA CREATION OF A SIGNIFICANT RISK TO AVIATION SAFETY - SHELLHARBOUR / WOLLONGONG AIRPORT, NSW

16th April 2020
The Hon Michael McCormack MP
Deputy Prime Minister
Minister for Infrastructure and Transport
PO BOX 6022, House of Representatives
Parliament House
Canberra ACT 2600, Australia

Mr Shane Carmody
Director of Aviation Safety
Civil Aviation Safety Authority
GPO BOX 2005
Canberra ACT 2601, Australia

Mr Chris Monahan
Executive Manager, National Operations and Standards
Civil Aviation Safety Authority

Deputy Prime Minister,

I write to you on behalf of the Aircraft Owners and Pilots Association of Australia (AOPA Australia), seeking your direct response regarding the Civil Aviation Safety Authority’s creation of a significant risk to aviation safety at YWOL in New South Wales, as a result of the proposed Energy Australia Tallawarra B open cycle gas turbine facility.

CASA recently determined that construction of an open cycle gas turbine electricity generation plant at Tallawarra, known as Tallawarra B, producing a plume with a vertical velocity of 6.1 m/s at 700 feet above ground level, within the circuit of Shellharbour Airport, does not pose a risk to the safety of aviation – a decision that directly contradicts aircraft manufacturers hard data that demonstrates such levels to be unsafe.

Do you consent to CASA creating this significant risk to aviation safety at Shellharbour Airport (YSHL), where there is currently none?
AOPA Australia understands that you, and all of government, are extremely busy at this time of crisis for our country, and indeed, the world. Therefore, we strongly recommend that you stay the CASA decision to proceed with the construction of this open cycle gas turbine at Tallawarra, in the circuit of Shellharbour Airport, until Government and industry have time to properly review this incorrect safety assessment by CASA.

AOPA Australia and the aviation community are feeling considerably frustrated by CASA on this matter. AOPA Australia presented hard evidence to Energy Australia and CASA, using approved data from the pilot operating handbook of the ubiquitous Cessna 172, to show that even a plume rise with a vertical velocity of 4.3 m/s poses a risk to light aircraft arriving at or departing from Shellharbour Airport. NSW Planning are aware of our concern on this matter.

Aircraft manufacturers data show that a plume with a vertical velocity of 6.1 m/s will stall the wings of the following aircraft in the circuit of Shellharbour Airport – The Cessna 172N, the Piper Archer II, the Jabiru J160, the Foxbat A22 and A22LS. All these aircraft types frequently use Shellharbour Airport. If the wings of an aircraft are stalled, the pilot risks losing control of the aircraft, and aircraft loss of control at circuit height and below invariably results in a fatal accident.

Do you consent to CASA creating this significant risk to aviation safety at Shellharbour Airport (YSHL), where there is currently none?
CASR 1998 regulation 139.370 makes it very clear that “CASA may determine, in writing, that a gaseous efflux having a velocity exceeding 4.3 metres per second is, or will be, a hazard to aircraft operations because of the velocity or location of the efflux.”

Advisory Circular AC 139-05 (0) – Guidelines for Conducting Plume Rise Assessments” was the AC current at the time of conditional approval of Tallawarra B, the condition being that the plume not pose a risk to the safety of aviation.

AC 139-05 (0) is quite clear about the risk a plume with vertical velocity of 4.3 m/s poses to aircraft arriving at or departing from an airport. AC 139-05 (0) states:

“2.2 CASA has identified that there is a need to assess the potential hazards to aviation because the vertical velocity from gas efflux may cause airframe damage and/or affect the handling characteristics of an aircraft in flight.

2.3 The stability of an aircraft is especially critical during periods of high pilot workload, such as when the aircraft is being manoeuvred at low altitudes with flaps extended and/or gear down.

Typically, this includes the initial take-off climb and the approach to land - when the
aircraft is in the vicinity of an aerodrome.”

AC 139-05 (0) goes on to say:

“4.2 Aviation authorities have established that an exhaust plume with a vertical gust in excess of 4.3 metres/second (m/s) may cause damage to an aircraft airframe, or upset an aircraft when flying at low levels.

4.3 Low level flying operations are typically conducted during: approach, landing and take-off”

CASA updated the advisory circular on this matter twice during the period of debate over the risk this project poses to the safety of aviation,
the last time in Jan 2019. AOPA Australia finds it incomprehensible that in this most recent update, CASA changed the need for a proponent of any such project to even have to discuss the matter with CASA or anybody else if the proponent’s calculations show that the plume generated has a velocity less than 6.1 m/s. This change was made without the presentation of a safety case, or explanation to the aviation community of what had changed to cause this shift in CASA’s thinking. More importantly, this change opened the way forward for the Tallawarra B facility.

Do you consent to the changes CASA have made to Advisory Circular AC-139-05 (3), creating a significant risk to aviation safety and directly contradicting aircraft manufacturer data?

AOPA Australia opposes the assessment CASA has made to determine that a plume with a vertical velocity of 6.1 m/s does not pose a risk to the safety of aviation – as it directly contradicts aircraft manufacturer data.

AOPA Australia’s calculations, using approved data from pilot operating handbooks, demonstrate that even a plume with vertical velocity of 4.3 m/s poses a risk to the safety of light aircraft arriving at, departing from, or training within the circuit of Shellharbour Airport. Energy Australia and CASA were presented with these calculations by AOPA Australia, prior to CASA’s decision on Energy Australia’s Aviation Impact Assessment on this matter to CASA. This advice is attached for your information.

It is CASA’s role to protect the aviation ecosystem, protecting those who are most vulnerable and in many ways, unable to protect themselves. CASA’s decision on this matter not only fails to protect the aviation ecosystem, it creates a risk to the safety of aviation that currently does not exist.

As our Minister responsible for Aviation, would you please enforce a stay on the implementation of this decision until Government and Industry have been afforded appropriate time to properly asses the risks that this project poses to the safety of aviation, as it is simply too late once it has been built?

Thank you for your consideration on this matter.

Yours Sincerely,

BENJAMIN MORGAN
Chief Executive Officer
Aircraft Owners and Pilots Association of Australia (AOPA Australia) 

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MTF...P2