As an aircraft operator (both powered and sailplanes), I have flown into and at the Hunter Valley Gliding Club at the Warkworth airfield. The first time I attended the site was from the air (which is important as it reduces opportunity to gain local knowledge in an unpressured environment - distinct from a higher pressure workload environment of an aircraft cockpit).

As both a sailplane pilot and a power pilot (that has flown into this airfield as my first visit to this site) I must make absolutely clear that the installation of power lines in the direct vacinty of the airfield in-line with its approach/departure and circuit path poses a significant risk to the safety of human life.

I strongly believe that by placing these powerlines where proposed at the proposed height that a high probability exists that preventable human casualties will be facilitated.

Why? Powerlines are hard to see and extremely dangerous to aircraft. You are placing them in close proximity to a high-movement (of aircrafts) location.

Recreation pilots (including many that are training at this site) are at great risk of being involved in a mistake with these transmission lines so close. Aviation is an error intolerant activity and as such a mistake is fatal. I invite those considering this feedback to search through light-aircraft fatalities related to wire-strikes.

I highly encourage a comprehensive and genuinely consultative process be undertaken with the airfield operator (the Hunter Valley Gliding Club) with genuine intent to properly mitigate the aviation risks that will present to the existing community operator.

In what is a highly safety conscience country where no workplace fatalities are acceptable this matter should similarly be considered as an unacceptable risk to human life that is obvious from the outset. It is absolutely unreasonable to subject existing recreational aviation users and their families to this risk of death on the basis that if it is too risky they should no longer operate at their airfield.

To whom it may concern,
Please see attached submission for full details.
NCC welcomes the opportunity to provide feedback on the Environmental Impact Statement (EIS) for the Hunter Transmission Project (HTP).
The HTP is a critical project in NSW’s transition to renewable energy.
It is essential in delivering renewable energy generated in the Central-West Orana and New England Renewable Energy Zones (REZs) to the eastern seaboard. The HTP has already faced delays and is not expected to come online until November 2029. Delivering the HTP without further delays is a precondition for NSW remaining coal-fired power plants to close on schedule and to meet the state's emission reduction targets.
A timely renewable energy transition is necessary to safeguard nature and communities in NSW.
Climate change poses one of the biggest risks to nature, through impacts including drought, bushfires, storms, ocean acidification, sea level rise and global warming. Many plants and animals cannot adapt to the effects of climate change. NSW has 1018 plant and animal species and ecological communities that are at risk of extinction, with climate change, habitat destruction, and invasive species the key drivers.
The bushfires and floods over the last few years have given us a taste of what is to come if we don’t take action to prevent climate change. The Paris accord states that to limit global warming to 1.5 degrees and prevent catastrophic climate events and mass extinction we must reduce emissions by 43% by 2030. NSW has legislated emissions reduction targets (based on 2005 levels) of a 50% reduction by 2030, 70% by 2035, and 0% (achieving net zero emissions) by 2050.
NSW’s ongoing reliance on coal-fired power means more blackouts and higher energy-prices. We need to build renewable energy generation, storage, and transmission in a timely manner to reach our emissions reductions targets, minimise the impacts of climate change on our environment, provide reliable energy for our state, and bring down energy prices to alleviate cost of living pressures.

The HTP falls short of nature positive goals
While NCC appreciates the important role that the HTP plays in the state’s renewable energy transition, the impacts on species and ecological communities are very significant. We are concerned that the design process resulted in the route being diverted off cleared private land and into critically endangered ecological communities (CEECs) in state forests. For example, the proposed route cuts through the known breeding bonds of the endangered Littlejohn’s tree frog, presenting a serious threat to their habitat.
It does not appear that a cost-benefit analysis has been undertaken to enable proper comparisons of the various route options, considering the full range of social, economic and environmental costs and benefits. There should be stronger consideration of alternative routes that would substantially avoid the losses to biodiversity and cultural heritage of the proposed route.
As Ken Henry’s review of NSW biodiversity laws found, all development must move to a nature positive framework. Nature positive means there has been an improvement in the diversity, abundance, resilience and integrity of ecosystems from an agreed baseline.
Achieving a nature positive future, as the NSW government has committed to in the NSW Plan for Nature, includes halting and reversing biodiversity loss, setting targets for landscape conservation and restoration, and requiring genuine avoidance of impacts before biodiversity offsets are considered.
These principles have not been adequately upheld in the in the HTP EIS. The total greenhouse gas emissions from the project during construction are estimated to be up to 644,384 tonnes of CO2-e per year (EIS Section 22.2.3, page 953). Around 20% of total emissions are attributable to native vegetation clearing. These emissions should be offset through carbon credits, or preferably, avoided by considering an alternative option that involves much less clearing of native vegetation.

NCC’s principles and recommendations for a nature positive renewable energy transition
As outlined in our joint statement, Strengthening NSW Renewable Energy Zones, signed alongside 16 organisations from the Hunter and New England REZs, our key recommendations for the NSW government are:
- Genuine engagement and consultation with First Nations communities must remain a central part of the planning, construction, operations and decommissioning of renewable energy projects
- Identify ecological protection and restoration priorities for each Renewable Energy Zone and require developers to contribute to specific nature positive environmental regional outcomes
- Develop regional community benefit plans and strengthen developer consultation with communities

Offsets do not compensate for the biodiversity impacts of the HTP
Should the project proceed on the route as outlined, it should be acknowledged that offset liabilities generated cover only the directly impacted species and ecological communities and do not reflect indirect impacts on loss of habitat continuity or cumulative impacts.
The EIS biodiversity assessment does not go beyond the Biodiversity Assessment Method (BAM). This focuses on threatened species impacts for the purpose of calculating offset credit liabilities under the Biodiversity Offset Scheme. It fails to consider wider biodiversity impacts such as fragmentation of intact natural areas, movement barriers (such as vehicle tracks), habitat and population thresholds, impacts on non-threatened species, and disturbance effects, such as fire, pests and weeds.
The offset calculations, therefore, significantly underestimate impacts and the biodiversity credit liability for the HTP should be higher than the amount calculated by the BAM.
The NSW government has acknowledged the offsets scheme under the BCA is not fit for purpose and is undertaking reform. NCC does not believe offsets can compensate for impacts, however for as long as the offset regime prevails, we believe that offset credits should go beyond compensating for harm. For example, if 141 Ha of Central Hunter Grey Box–Ironbark Woodland are set to be impacted, we believe 282 Ha of local Central Hunter Grey Box–Ironbark Woodland should be protected.

Greater targets, ambition and clarity are needed to protect and restore biodiversity
The Hunter Conservation Investment Strategy sets out strategic conservation priorities and actions for the region, for offsets retirement and beyond.
NCC welcomes the development of the Regional Conservation Investment Strategies (the Strategies), not only for the Hunter but for all REZs in NSW. Regional level planning for conservation helps consider cumulative impacts on biodiversity in the region across developments and allows for frontloading biodiversity considerations and habitat continuity into planning for REZs.
However, the regional conservation investment strategies need to be strengthened by including:
- no go areas for development and linking more directly to the planning system
- specific and ambitious conservation and restoration targets
- clear funding commitments for actions in line with the Strategies that go over and above offset funds
- opportunity for public consultation and input to the development and review of the Strategies
There should be limits on “broader conservation actions” related to target species and ecological communities as it is not appropriate for offset money to be used for research, for example. There must be on-the-ground conservation outcomes.

Priority should be given to extending and rationalising key conservation reserves in the Hunter
We believe it will be challenging to retire so many offsets via biodiversity stewardship agreements in a timely manner. The likelihood of retiring the total offset liability within the 3-year Strategic Offset Delivery Agreement (SODA) delivery period via biodiversity stewardship agreements appears slim.
Priority should therefore be given to extending and rationalising key conservation reserves within the region, consistent with the Hunter Conservation Investment Strategy and areas identified as significant climate corridors. This should not rule out other options where practical. A focus on reserve acquisitions will allow for greater habitat connectivity and resilience, compared with stewardship agreements that are likely to include geographically separate sites.
Sites that are worthy of consideration are outlined in the table in the attached submission.

Thank you for the opportunity to participate in this consultation.

Your key contact point for further questions and correspondence is Eve Altman, Clean Energy Campaigner, available via [email protected] and (02) 9516 1488. We welcome further conversation on this matter.
Yours sincerely,  
Jacqui Mumford
Chief Executive Officer
Nature Conservation Council of NSW

See attachment. In summary, my view is that the economic assessment of the HTP has not been completed to a satisfactory level. The absence of details about economic impacts and the absence of a community and employment benefits program have prevented genuine, worthwhile economic assessment of the proposal. A major re-visiting of the economic assessment required by the SEARS should be demanded.

Please see attached my submission regarding the EIS for the Hunter Transmission Project.
It is important to note that I am in support of the project and what it intends to achieve, however I have a number of concerns regarding the EIS as outlined in the attached document.

My comments are detailed in the attached submission

I am writing my comments on a part of this project that relates to the location of the powerlines in the vicinity of the Hunter Valley Gliding Club.
I write my comments in my capacity in aviation as an experienced glider pilot, instructor, power pilot. I also write my comments in my capacity as a retired engineer and project risk manager and safety manager on major gas projects.
The comments refer to the Aviation Impacts Report, Section 5.6 on Uncertified aerodromes, particularly Warkworth Aerodrome which is operated by Hunter Valley Gliding Club. I note that in Table 6, Uncertified Aerodromes within 10 kilometres of the HTP corridor there are four aerodromes listed within 10nm. The Warkworth aerodrome is located 1.1nm from the proposed powerline, the closest of those four aerodromes. The table states “No adverse impact if mitigation is in place”. The report’s so called mitigations are flawed and therefore the powerline is greatly impacting safety from the airfield.
A risk assessment has not been provided, and no risk assessment has been conducted with the Gliding Club. The data proposed in Paragraph 7 of that section is flawed and displays no understanding of gliding operations. The quotes in italics below signify quotes from the report.
Normal Climb out of the Glider and Tug
“The glider and tow plane combination, which are used at Warkworth Aerodrome, are usually airborne within 600 metres from the start of take-off point and, in a worse case, take off with a fully ballasted glider on a hot day within 1000 metres from the start of take-off point. This indicates that a tow plane/glider combination taking off towards the east and climbing at an a rate of approximately 500 feet per minute and an indicated airspeed of 60 nautical miles per hour (knots) would take approximately 1 minute to reach the HTP Corridor and would be at a height of 500 feet or more above the runway, and therefore more than 220 feet above the HTP by the time they reach the transmission line.” Fully ballasted gliders on tow do not climb at 500 fpm and this can be as low as 200 fpm. That means that heavy gliders are perilously close to the powerline on initial climb. In summer, which is the best time of the year for gliding, temperatures are higher and the density height higher, meaning tug performance is degraded.
HVGC conducts a significant amount of pre-solo and pre-licence (Glider Pilot Certificate) training. In training, there needs to be safety margins built in to the gliding operations.
Abnormal Climb out of the Glider and Tug
Should there be a problem with engine performance of the tug, climb rate performance in impaired, the glider has to release and the tug and glider must conduct an emergency landing. Should this occur, the current procedures are to land in the open paddocks to the north-east of the aerodrome. This is the proposed location of the powerline and therefore emergency options are so limited to be dangerous to the tug pilot and glider pilots, resulting in aircraft damage at least, and casualties at worst.
Mitigations
The aviation report displays ignorance of the limitations of gliding operations in the vicinity of obstacles.
“Tow pane pilots should, wherever possible, avoid climbing the combination in the downwind leg of the circuit and plan their departure so as to keep the glider within gliding distance of the airfield. “While it is usual for an aircraft to maintain runway heading until it reaches 500 feet AGL, the pilot in command of a tow plane/glider combination (on tow) is permitted to make deviations to maximise safety for the combination during the take-off, so as to remain over land able terrain”. The powerline is not described as ‘landable terrain’. It is an obstacle. The safety mitigation of being able to fly over landable terrain to the NE is taken away by the location of the powerline.
Prohibition of Training for Outlandings
“Emergency procedures and outlanding training by the HVGC can be conducted in the area between the aerodrome and the HTP corridor, or beyond it.” This is incorrect. The only suitable landable area for outlanding training is now under the proposed powerline.
Gliding Events
HVGC holds regular events where it invites gliders and pilots from around the country. These gliders are generally vintage gliders with low performance. For versatility and safety, the airfield needs to have multiple options for takeoffs, circuits and landings. These events are a key strategy for the club to increase its activity and financial status. The powerline location would likely prevent these events from continuing.
Landings
Gliders need multiple options for circuits and landings. High performance gliders can easily have lower heights before they join circuit. No glider pilot will want to be approaching a landing (remember no engine) over powerlines. The pilot must manage lift and sink in executing landings as there is no “go-around” possible.
Worst Case
If this powerline location in the vicinity (only 1.1nm) of the airfield goes ahead, gliding at Warkworth Aerodrome will suffer to the point where the club becomes unviable. There is much infrastructure and many gliders that would have to find another aerodrome to operate from, which are very rare. The club has not assessed the cost and logistics of moving to and purchasing a new site, but I estimate it would be in the vicinity of at least $1million. HVGC is one of the closest gliding clubs to the metropolitan area of northern Sydney and the general Hunter Valley area. It serves a strong function of providing basic aircraft training and scholarships for young people.

In summary, the location of the powerlines has enormous financial and safety impacts to the Hunter Valley Gliding Club and a re-assessment of its location in the close vicinity to the Warkworth Aerodrome is warranted on a social, financial and safety basis.