[Peetwo]

HOT OFF THE PRESS! via the EMAC (Evans Head Memorial Aerodrome Committee) -

Reference:

...The Murky Machiavellian and his side-kick Dolan were granted all manner of latitude to make the sale of airport land (Commonwealth land) to developers as attractive as possible. Hell they even ‘finessed’ some definitions to assist. All in the name of progress aligned with public safety of course....

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Ref: https://auntypru.com/forum/thread-30-pos...ml#pid9711

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...For example; there is a plan to build a large hospital in a regional centre; it is to have all the toys – including a helipad. Bravo. There is even an approach path mapped out for the Choppers which is touted as ‘the best’. For many reasons, that ‘selected’ path suits many people and puts a nice shine on the ‘spin’ delivery. Cool Banana’s; right. Well, answer me one question – just the one, a short one. Do you know what a Flying Fox is?...

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“Flying-foxes are the largest flying mammals in the world, acting as long-range seed dispersers and pollinators for a large number of native trees.”

“The maps below show the general location of flying-fox roosts in Queensland recorded by the department, and include continuously and periodically (seasonally or irregularly) used roosts. The exact location of roosts may vary within a small localised area.”

Around dusk, grey-headed flying foxes leave the roost and travel up to 50 km a night to feed on pollen,

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..Well done class; all correct – now then, for Choc Frog; one last question. How would you like to be a patient flying in a helicopter to hospital, at low level <500' around about tea time or breakfast time through a 1.5 kilometre ‘launch zone for hundreds of flying foxes? For a bonus point, how many Fruit Bats to kill a Chopper?. Give up, can’t guess, well wait a while and the answer will become clear – the route to the emergency ward through the Fruit Bat launch zone is ‘approved’. Consequences? Wuzzat - Never heard of ‘em. The local airport development plan has - but 'what-the -hell'..

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Ref: https://auntypru.com/wp-content/uploads/...-2018.docx

Media Release

Helicopter Flight Path for Tweed Valley Hospital in Flying Fox Buffer Zone: Why wasn’t this serious risk included in the aviation assessment?

The Evans Head Memorial Aerodrome Committee Incorporated has serious concerns about the adequacy of the Aviation assessment for the proposed Tweed Valley Hospital rooftop Helicopter Landing Site, and the appropriateness of the location because of risk to public safety.  
The Committee has formed the view that the proposed location for the hospital is not appropriate because of significant risk of helicopter collision with flying foxes from a nearby colony.

 “In our view this aviation/flying fox conflict has serious ramifications for the siting of the hospital because of the need for helicopter access for emergencies.  If the hospital is to have a helicopter emergency facility at all then the hospital needs to be relocated to a safer area. 

As the hospital is only in the planning stage this is the ideal opportunity for the State government to relocate the proposal from the current site to one which is safer.    There is not only the risk to the helicopter and its crew and retrieved patient to consider with the current location, but also the community at large should a helicopter be impacted en route to the hospital or on call-out.  Risks to the public must be reduced as much as possible and the State government should discard any use of an “affordable risk” model in its decision-making.  It seems ironic to us that the State should be going to all this trouble to create a health facility to save human life while putting the public at a risk which is clearly avoidable.  This risk cannot be ignored.”

Dr Richard Gates, President of the Committee said today that “the flight path for the helicopter crosses the buffer zone for an identified flying fox colony not far from the hospital[1](see Figure 1).   The helicopter would be flying at low level in this area for more than a kilometre increasing risk of conflict as at airports.  Flying foxes don’t tend to get out of the way.  They are a known risk to aviation.”

Dr Gates said he was surprised when he read the aviation review on the rooftop Helicopter Landing Site (HLS) that there was no mention whatsoever of the flying fox risk for the proposed Tweed Valley Hospital location.  

“The organisation which prepared the report for the government has prepared many such reports for them and we would have thought by now that a risk assessment for birds and bats for northern NSW locations would be considered ‘routine’ given their well-known presence.  Clearly the Health Department Guidelines for HLS, which were recently revised, are not up-to-date and require the addition of such an important consideration and assessment.  Federal National Aviation Safeguards have identified these risks for some time now (see footnote 2)”.
“Birds and flying mammals such as the echo-locating bats and flying foxes are identified in the National Airports Safeguarding Framework Principles and Guidelines (see paragraph 26).  While the HLS is not an airport, well-known risks to aviation MUST be canvassed particularly when there is an established Plan of Management for Flying Fox in the Tweed Valley area and the matter of aviation risk has been canvassed in that Plan for both the existing hospital and the Gold Coast Airport.  The proposed new 

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[1]https://www.tweed.nsw.gov.au/Documents/E...t_Plan.pdf (see pages commencing 100)

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hospital site is much, much closer to the bat colony.  In our view this is a serious problem requiring urgent attention before any more work is done on the hospital at the current site. 

“Wildlife strikes and / or avoidance can cause major damage to aircraft and / or reduction of safety.  The consequences of wildlife strike can be influenced by the number and size of wildlife involved, phase of flight and the aircraft part hit by the wildlife”.[1]

 “The vast majority of wildlife strikes take place at or close to airports.  Almost all involve birds and flying mammals (such as bats and flying foxes)”[2].  In the case of the proposed Tweed Valley Hospital the flight path to access the hospital is at a low level and well within the heights the bats use to and from their colonies”.  

The NSW North Coast is not without its tragedies relating to bird strike.  “The loss of an F-111 and its personnel to bird strike many years ago at Evans Head is an example close to us[3],” said Dr Gates.   

He went on to say that his committee also has concerns about the independence of the SEARS aviation report prepared for the State government[4]. 

The consultant referred frequently to the NSW Health Department Guidelines for Helicopter Landing Sites[5]and stated clearly that they were “best practice”, and certainly from our reading implied that they were better than existing pertinent federal government guidelines which had yet to be finalised. 
 
Indeed the consultant made comment on the apparent tardiness of the federal government in this matter:  “..new rules will form Civil Aviation Safety Regulation (CASR) Part 139R, however it is not expected that they will be completed any time soon” [emphasis ours].   

In our view the consultant’s comment is hardly a vote of confidence in the Civil Aviation Safety Authority (CASA) which is charged with aviation safety matters under its Act[6].  And in our view the comment begs questions about CASA and the federal government and delays in matters involving human safety and human life as they have with Public Safety Zones around Australia’s airfields[7]?
 
When we reviewed these State Health Guidelines about Helicopter Landing sites we noted that the consultant who prepared the Aviation Assessment for the proposed Tweed Valley Hospital was also cited very frequently in the Guidelines.  

We formed the view that the consultant to the NSW government should have declared this fact about the use of its material in the Guidelines in their assessment particularly when using them to guide their hospital HLS review.   The consultant may well be the best in the field and that may be why their materials were used by NSW Health, but if this is so why not declare this fact to allay any concern about independence of the assessment process?

We also noted in our review that the consultant has provided a number of reports about HLS for NSW hospitals which also raised questions for us about the tender processes for engagement of consultants specialist in this area.  Is there a tender process and how are consultants selected?  If not, why not?  These are questions which must always be asked in any economy driven by ‘the market place’, a 

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2 https://infrastructure.gov.au/aviation/e...line_C.pdf 
[2]Ibid. 
[3]https://aviation-safety.net/wikibase/wiki.php?id=137482 
[4]https://www.planning.nsw.gov.au/-/media/...15-12.ashx 
[5]NSW Health GL2018_010 Guidelines for NSW Hospital HLS  
[6]http://www7.austlii.edu.au/cgi-bin/viewd...aa1988154/ 
[7]https://www.aph.gov.au/Parliamentary_Bus.../INF/index 

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hallmark of the current State and Federal governments, to protect the public interest.  There doesn’t seem to be easily-accessible publicly-available information about this process.  

Dr Gates said that in view of the identified flying fox problem for the proposed hospital site not raised in the Aviation Assessment, the State government needed to review its location, the HLS Guidelines which seemed to be deficient with regard to aviation risk assessment, mechanisms for consultant choice and declaration requirements so that the public has confidence in the planning processes for the new hospital.  The public interest with focus on public safety must always be ‘front-of- mind’.
       
He said his committee also had concern that the solution the government might find for the flying fox problem was a lethal one: The colony to be destroyed ‘in the public interest’ so that there was no longer any risk to the helicopters! “This would be an incredibly dumb solution given the important role flying foxes play in the productive economy of our forests[1][2], something the State government already knows! 
There are better solutions to the current problem such as a new location for the hospital.  Health claims it reviewed 30 potential sites for the hospital[3].  Surely one of these would be better than the current site? The State government needs to make the site evaluation process public so that we can see how the current site was chosen.  Public access to this process is critical to public confidence in our institutions and the political process for this controversial hospital site.  
  
Concluding Remarks

Clearly our evidence suggests that the evaluation process used by NSW Health in selection of the site was deficient.  Where was the due diligence for public risk and why was the flying fox matter missed when it figured prominently in other documentation available to the State government and a report referenced by the consultant?    Certainly Tweed Council raised its concerns publicly with regard to the impact the proposed hospital at its current location would have on the local biology including the flying fox[4].   Surely that query from the local council in whose jurisdiction the hospital is to be built should have set alarm bells ringing about flight risks and proposed location of the hospital?  

 But more than that why was the Civil Aviation Safety Authority, which is charged with aviation safety and related standards for Australia, not involved in this critical process as an independent authority? 

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[1]https://environment.des.qld.gov.au/wildl...tance.html 
[2]https://www.aph.gov.au/Parliamentary_Bus...37%2F24314 
[3]https://www.hinfra.health.nsw.gov.au/new...pital-site