Documentary and regulatory pathway

Noise Management Plan

A source-led guide to the available October 2022 Noise Management Plan, its relationship with the endorsed Noise Compliance Testing Plan, EPA documentary custody, auditor verification correspondence, Freedom of Information releases and the later planning permit amendment pathway.

Reading position: This page distinguishes the governing framework, the NMP's technical content, documentary custody and later administrative reliance. It does not determine compliance, validity, breach or legal effect.
Document identity

The available October 2022 document

The document released through the EPA Freedom of Information record is titled Lal Lal Wind Farm — Noise Management Plan, Project No. 0467385, Version 3.0, dated 18 October 2022. Its document history records Draft, Final 01, Final 02 and Final 03 revisions.

NMP document details and revision history showing Version 3.0 dated 18 October 2022

Document details and revision history

The extract records Version 3.0 and Final Revision 03 dated 18 October 2022.

NMP extract summarising regulation 131E requirements and auditor review obligations

Regulation 131E and auditor pathway

The NMP records procedures required by regulation 131E and states that an auditor is to review the NMP.

Relationship with the endorsed methodology

What the NMP says about the NCTP

The NMP states that the endorsed Noise Compliance Testing Plan provides the complete operational measurement procedure and that, where a conflict exists, the NCTP takes precedence. It also identifies the Marshall Day Acoustics NCTP and Background Noise Monitoring Report as the documents from which operational limits were derived.

NMP extract identifying the Marshall Day NCTP and background noise monitoring report

Stated source documents

The extract identifies the Marshall Day NCTP and Background Noise Monitoring Report. The later SLR K15aa Baseline Report dated 16 February 2021 is not identified in this stated reference pathway.

NMP extract stating the NCTP takes precedence where a conflict exists

NCTP precedence and alternative locations

The NMP states that the NCTP takes precedence where a conflict exists and records that no alternative measurement points were identified at the time of writing.

Technical comparison

Preferred operational measurement locations

The endorsed NCTP and the October 2022 NMP do not present the same preferred operational measurement-location framework. This comparison concerns preferred measurement locations, not the separate receiver noise-limit tables reproduced in the NMP.

ReceiverEndorsed NCTPOctober 2022 NMPSection
H18aaPreferred locationPreferred locationElaine
K15aaPreferred locationPreferred locationElaine
K34aaPreferred locationNot identified as a preferred locationYendon
L18aaPreferred locationPreferred locationElaine
M29aaPreferred locationNot identified as a preferred locationYendon
N31abPreferred locationNot identified as a preferred locationYendon
Endorsed NCTP extract listing six preferred operational measurement locations

Endorsed NCTP

The approved NCTP identifies six preferred locations, including the Yendon receivers K34aa, M29aa and N31ab.

October 2022 NMP extract listing three preferred compliance measurement locations

October 2022 NMP

The NMP identifies H18aa, K15aa and L18aa as the three preferred measurement locations.

Background-noise and reporting procedures

Further technical extracts

These extracts show how the October 2022 NMP describes background-noise adjustment and reporting. They are presented as statements made by the NMP, not as independent record findings.

NMP extract on adjustment for background noise levels

Adjustment for background noise

The NMP states that pre-operational background-noise data is to be used to adjust compliance-monitoring results.

NMP extract on operational noise reporting and six-week submission period

Operational noise reporting

The NMP states that compliance reports are to be submitted to EPA within six weeks of completing each stage of monitoring.

EPA documentary custody

NMP chronology

The dates are recorded because EPA's later descriptions of the NMP post-date the October 2022 document and the earlier documentary-use record.

18 October 2022

Version 3.0 prepared

The disclosed NMP records Final Revision 03.

November 2023

Auditor verification requested

EPA later stated, in correspondence dated 21 June 2024, that it requested auditor verification in November 2023.

31 January 2024

EPA documentary-use statement

EPA identified NMP project 0467385 among documents it had used when assessing compliance.

4 March 2024

FOI-002-2024 decision

The October 2022 NMP was disclosed through the earlier EPA FOI process.

22 May 2024

Revisions said to be continuing

EPA stated that the NMP was still undergoing revisions and had not yet been reviewed by an EPA-appointed environmental auditor.

21 June 2024

Earlier verification request confirmed

EPA stated that auditor verification had been requested in November 2023.

18 July 2024

Revised NCTP secondary-consent application withdrawn

The proponent requested withdrawal of the revised NCTP application submitted on 12 October 2023 after receiving further advice that additional areas required revision. The project stated that it would continue working with Marshall Day on the necessary amendments.

23 January 2025

Internal review description

EPA stated that it had seen a draft NMP but had not been provided with a completed final NMP.

4 February 2025

Date of draft clarified

EPA advised that the draft NMP was dated October 2022.

25 September 2025

FOI-100-2025 decision

The same Version 3.0 NMP dated 18 October 2022 was again disclosed in the later FOI process.

15–18 May 2026

Permit amendment and DTP clarification request

Following issue of the amended permit determination, the Trustee sent the October 2022 NMP and a request for administrative clarification to the nominated DTP contact on 18 May 2026.

Consolidated primary-source pathway

Noise Management Plan — Primary Document Record

A consolidated primary-document record brings together the October 2022 NMP, EPA documentary use and FOI custody, the environmental-auditor pathway, the proposed NCTP revision and withdrawal record, and the later planning-permit transition.

The October 2022 document records Version 3.0, Final Revision 03. Within that NMP, the draft status is expressly attached to Revision 5 of the NCTP, and the NMP states that the relevant NCTP chapter would be superseded by an updated NCTP prepared to satisfy the Planning Permit noise conditions.

EPA later identified NMP project 0467385 among documents it had used when assessing Lal Lal Wind Farm compliance and confirmed that it had requested auditor verification in November 2023. The May 2024 FOI decision records that EPA did not hold the requested auditor verification. The later revised-NCTP secondary-consent application was withdrawn on 18 July 2024 before endorsement, while the project stated that revision work would continue.

Later EPA and operator correspondence describing the October 2022 NMP as a draft or as still being revised is preserved in the record and should be read alongside the document's own Final revision history and the separate NCTP revision pathway.

Documentary limit: The compilation does not determine the legal effect of the NMP, compliance with regulation 131E, or the consequence of the withdrawn NCTP amendment pathway. It places the primary documents in chronological sequence so the record can be independently followed.
Source correspondence

Read the administrative record directly

The source documents are presented separately so readers can distinguish the NMP's technical content from EPA correspondence and the later Trustee notice to DTP.

EPA document-use email — 31 January 2024
Identifies NMP project 0467385 among documents used by EPA in assessing compliance.
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EPA FOI-002-2024 decision — 4 March 2024
Earlier FOI decision associated with disclosure of the October 2022 NMP.
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EPA revisions email — 22 May 2024
States the NMP was undergoing revisions and had not yet been auditor reviewed.
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EPA verification email — 21 June 2024
States EPA asked for auditor verification in November 2023.
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EPA internal review manager email — 23 January 2025
Records EPA's position that it had seen a draft but had not received a completed final NMP.
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EPA draft-date email — 4 February 2025
States that the draft NMP was dated October 2022.
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EPA FOI-100-2025 decision — 25 September 2025
Later FOI decision in which the same October 2022 NMP was disclosed.
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Trustee request to DTP — 18 May 2026
Places the October 2022 NMP, FOI history and auditor-verification chronology before the nominated permit-amendment contact.
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Planning permit amendment

Transitional Condition 27A

The amended permit records that compliance with the endorsed NCTP and complaints plan is to be maintained until an NMP has been prepared and implemented in accordance with regulation 131E. The Trustee's 18 May 2026 correspondence sought clarification of how the October 2022 NMP, the EPA documentary record and auditor-verification history were reconciled within that transitional framework.