Fauna and aircraft
In addition to the effect of wind turbines and industrial noise on human
health, wind turbines have a range of other detrimental environmental impacts
on the surrounding environment that require attention. Term of reference (g) of
this inquiry directs the committee to examine the 'effect that wind towers have
on fauna and aerial operations around wind turbines, including firefighting and
This chapter will examine the following issues:
modification of sensitive ecosystems through land clearing
activities and interference in the flight zones of native birds leading to
serious injury and death;
impacts on visual amenity;
interference with aerial firefighting activities, resulting in
increased destruction of native vegetation and habitat during fire events; and
interference with crop management activities (including aerial application
of fungicides and herbicides that result in downgrading of crop quality and
yields (hence decreasing farmer's profits. and local economies).
The impact of wind farm development and operation on native fauna, in
particular native birds and bats, has been raised by many witnesses and
submissions to the committee. In its submission, Save the Eagles International
described wind turbines as '"ecological traps"—population sinks that
attract and kill millions of birds and bats year after year'.
There are a wide range of estimates as to the extent of fatalities caused
by wind turbines on aerial fauna. Ms Emma Bennett noted that 'only a limited
number of studies' had been conducted into the impact of wind farms on bird
mortality, and that estimates indicate that '2 000 to 8 000 birds [are]
annually killed across all wind farms in Australia'.
The Australia Institute contends that the 'average death rate is 1–2 birds per
turbine per year'.
Considering that there are currently 2 077 turbines in Australia, these estimates
seem to correlate.
However, a report on bird and avifauna mortality commissioned by AGL
Energy for its Macarthur Wind Farm found that 10.19 birds were killed by each
turbine in a 12 month period. This equates to over 1 400 birds killed at the
Macarthur Wind Farm alone and over 21 000 if extrapolated across the country. Despite
the apparent thoroughness of this monitoring exercise—4 surveys in 12
months—the authors of the report were concerned that the 'estimates of
mortality, however, are considered to be inaccurate due to the frequent removal
of carcasses by scavengers.'
Notwithstanding the debate over the number of mortalities, some
submitters argued that the number of deaths caused by wind farms were
insignificant compared to the 'higher rate of avian mortality that results from
collisions with automobiles, transmission towers and power lines, as well as
the damage done by domestic and feral cats which cause significantly more
The committee shares the concerns of many submitters that information on the
subject of avifauna mortality at windfarms is unclear and that more research in
this area is required with special consideration of those bird species which
Many submitters noted the high prevalence of native birds in areas
surrounding current and proposed wind farms. In her submission to the
committee, Councillor Marjorie Pagani noted that the region adjacent to the
proposed Mt Emerald Wind Farm in northern Queensland is a haven for many
species of birds and bats:
Our region (and my own property) is home to abundant raptor
and other bird life, and quolls, including the rare northern spotted quoll.
These have all been observed on my property. The containment of mass
destruction of habitats has not been sufficiently explained in the developer
applications. Nardellos Lagoon, a few kilometres from the centre of the range,
is a significant breeding area for Sea Eagles, Saris Cranes, Brolgas and a
major habitat for black swans. The range is a major migratory bird flight path,
for not only the raptors, but also the flying foxes. The developer has admitted
the flight path of these birds is at the height of the proposed turbines. It
has not acknowledged either the migratory species, nor the Nardellos breeding
lagoon in its report, nor has it acknowledged the extensive cropping in the
area and the bird numbers from that perspective.
Mr Alan Cole, a farmer in the Yass region of southern NSW highlighted a
number of the key species currently found at his farm, part of the proposed site
for the Yass Valley Wind Farm:
My farm sits in a valley located between the Black Range and
Mt Bowning just west of Yass. This valley is a raptor hotspot, with numerous
species of raptors including Wedge Tailed Eagles, Little Eagles, Sea Eagles
(from Burrinjuck Dam) and Peregrine Falcons (to name a few) frequent the area.
Whilst only two of these species are considered endangered, it is my opinion
that the Epuron proposed WINDPEG’s for the Black Range have the potential to
decimate local populations of these raptors.
Several submissions and witnesses highlighted two bird species that are particularly
vulnerable—the brolga (Grus rubicunda) and the Superb Parrot (Polytelis
The brolga is one of only two types of crane found in Australia. The NSW
Office of Environment and Heritage notes that the brolga population 'is very
sparse across the southern part of its range' and that the brolga is regarded
as being a 'vulnerable' species in both NSW and Victoria.
Mrs Susan Dennis, President of the Brolga Recovery Group, concurs noting:
The brolga is considered to be significantly prone to future
threats which are likely to result in its extinction; it is very rare in terms
of abundance. There are fewer than 500 remaining in south-west Victoria.
Mrs Dennis outlined the impact that wind farms have on brolgas.
There are three ways that wind energy facilities can impact
on the brolga: direct collision, barrier effects and, the most critical of all,
displacement from habitat. The brolga simply cannot afford to be displaced from
an already limited habitat. It can be quite clearly seen in the maps that there
are groups of wind energy facilities proposed and constructed in important
brolga habitat. The current evidence is that the brolgas are likely to be
displaced up to eight kilometres. So where do they go? Brolgas tend to use the
same habitat areas over many years, so it is not just a case of creating a
wetland somewhere else and hoping the brolgas will go there. Clearly, there are
no offset plans that can compensate for stolen habitat. And when wind energy
facilities are so close together in brolga habitat, there cannot be a zero net
impact and the requirement to avoid any cumulative impact is clearly
Mr Hamish Cumming, formerly a Brolga Recovery Group secretary, told the
committee that the issue relating to brolgas and wind turbines is one of
Studies have been done in America and Australia that show
that the turbines are displacing cranes—and brolgas are a crane—for a distance
of up to 14 kilometres but regularly a distance of six kilometres. Since the
Macarthur wind farm started—and I try to use all these people's own reports;
they are the best thing to use—their reports have said that 45 wetlands were
abandoned in the first 12 months, and 25 of them were potential breeding
wetlands, and no brolgas have successfully nested within six kilometres of
The Superb Parrot is another species that is under threat from wind farm
development and operation. Similar to the brolga, the Superb Parrot is listed
as a vulnerable species under the federal Environment Protection and
Biodiversity Conservation Act 1999 and at a state level in the ACT and NSW.
The Victorian Government has taken one step further, listing it as an
In his submission, Mr Cole observes:
The Yass District happens to enjoy the natural range of one
of the most beautiful and rare parrots found in NSW; the Superb Parrot.
It is understood that this threatened species is starting to
recover from the population loss it has experienced from habitat destruction. Of
great concern for the future of this species is the potential impact of wind
turbines in central NSW. The proponents of WINDPEG’s tend to trivialise these
The committee notes that the Superb Parrot is subject to the same
threats as the brolga—'direct collision, barrier effects and, the most critical
of all, displacement from habitat' as outlined by Mrs Dennis above. Mr John
McGrath states that 'the greater Boorowa area is a known breeding ground for
the Superb Parrot' and that any development in this area must consider wind
turbines as a key threatening process.
The committee is also concerned about the impact of land-clearing
activities related to wind farm development that result in the direct and
indirect deaths of fauna—birds, bats and other invertebrates. The Waterloo and
District Concerned Citizens Group noted that the Waterloo Wind Farm has
resulted in the 'loss of habitat of native and endangered birds and animals,
particularly eagles and other raptors'
The Tarwin Valley Coastal Guardians described the horror of finding four dead
koalas over a 4–6 week period as a result of land clearing to install a
One of these dead koalas can be seen in Figure 6.1 below. Mr John McGrath
shared his concerns about unexpected deaths in his submission:
We remain mystified as to why perfectly healthy and heavy
Wedged Tailed Eagles fall out of trees dead or are found in local paddocks in
the same condition dead. A fact that we believe as a family needs further
Figure 5.1: One of four dead koalas allegedly found by local residents at a
construction site associated with the Bald Hills Wind Farm
Source: Tarwin Valley Coastal Guardians, Submission
45, p. 45.
Inadequacy of bird and bat surveys
The committee has received evidence about the poor knowledge base that
exists within the environmental consultancies that prepare and submit
environmental approvals and management plans on behalf of wind farm proponents,
and the planning and environmental agencies that regulate and approve wind farm
This section will discuss examples of avifauna surveys conducted in conjunction
with wind farm development.
The bird survey conducted by Brett Lane and Associates as part of the
environmental approvals process for the Bald Hills Wind Farm was reviewed by Dr
Lucas Bluff in a report to the Tarwin Valley Coastal Guardians. This report
quoted the Victorian Government's independent Planning Panel as describing the
bird survey as 'a relatively low survey effort'. Not only was the total number
of hours completed for the bird survey manifestly inadequate, the quality of
the survey work was also questioned.
Most of the survey work was undertaken between 8.00am and 5.00pm, clearly not
in line with best-practice with the panel indicating that 'you really need to
start predawn and finish after dusk'.
Finally, Dr Bluff states that an inappropriate survey spatial design was chosen
and implemented. Dr Bluff is quite plain in his concluding observations on the bird
It has been acknowledged that the timing of Lane's survey
work was flawed, and that the result of this error is to reduce the apparent
utilization of the site by birds and potentially to miss movement patterns of
some species altogether. Therefore, the risk that the development would pose to
birds is unambiguously higher than that claimed by Lane.
Many of the same issues were apparent in the bat survey. A review of the
bat survey by the Planning Panel highlighted that a species known to the area
and of high conservation concern—the Bentwing Bat—was not located during these
surveys with the Panel acknowledging 'that Lane's bat survey work was
insufficient to quantify the presence of Bentwing bats at the site, and
recommended extended monitoring of the bat population and of bat kills'. An
expert on these bats, Dr Belinda Appleton, was more direct stating that:
The proposed wind farm should not be approved until the
necessary investigations into effects on bat mortality have been carried out.
This is not the only incidence where the results of a fauna survey have
been called into question. The fauna surveys conducted for wind farms in the
Boorowa area, in southern NSW, were appraised by Mr John McGrath:
Brett Lane and Associates basically self-admitted that they
did [no] more than small walk t[h]rough's of the area of some of the proposed
conglomeration of 360 wind towers stretching from the Hume Highway just North
of Yass through to the Rye Park Rugby area.
From my memory they claimed that they did a "walk
through" in May of small portions of this proposed conglomerations of
towers and stated that there were no Superb Parrots Polytelis swainsonii—That’s
exactly correct there are no Superb Parrots in residen[ce] in the Boorowa area
in May, the birds arrive from their Northern haunts in preparation for breeding
in very late August mid-September whereupon they build themselves up physically
for breeding by feasting on the blossom of the Yellow Box Eucalyptus melliodora, then after a hectic
period breeding of less than 4 months viz laying, setting on their eggs[,] hen[s]
only being fed mainly by the cock bird, raising their chicks to fledging,
fledging their chicks they all then depart again for their Northern haunts in
mid-January the next year. The greater Boorowa area is a known breeding ground
for the Superb Parrot.
Adjacent landholders to the Moorabool wind farm in Victoria, Mr and Mrs
John and Sue Dean noted the inadequacy of flora and fauna assessments:
Flora and Fauna studies were faulty. No level 2 survey was
undertaken for the Wedge Tailed Eagle. No specific survey was undertaken for
the Growling Grass Frog. No survey undertaken for the Powerful Owl and no
consideration given to the flight path of the Yellow Tailed Black Cockatoo. In
fact, there were only desk top studies done for most of the rare and threatened
species and no EES was requested by the Planning Minister.
In its submission to the committee, the Bodangora Wind Turbine Awareness
Group (BWTAG) raised a number of concerns about the Flora and Fauna Assessment
conducted for the Bodangara Wind Farm. These concerns focus on the inadequacy
of the biodiversity assessment and include:
- insufficient detail provided to support the assessment of impacts
on native flora and fauna;
insufficient detail provided with regard to avoidance measures;
inadequate details provided with regard to options for mitigating
impacts on biodiversity; and
the EA [Environmental Assessment] does not include a detailed
BWTAG found that there appears to be insufficient data in
the Flora and fauna Assessment to 'support the conclusions of the impact
assessment'. These concerns were also shared by the NSW Office of Environment
In its defence. the proponent asserts that a more detailed assessment is
not required as the wind farm site is 'an "overcleared" agricultural
landscape' of low ecological value. However, BWTAG argues that the value of the
remnant scattered paddock trees is 'constantly being underplayed':
Removal of a single tree from an over-cleared landscape can
have detrimental impacts to landscape connectivity for some threatened woodland
birds (see Doerr et al.'s (2011) work on Brown Treecreepers and threshold
distances for crossing gaps between habitat). Furthermore, wind turbines have
been found to reduce bird breeding habitat up to 500m (Pearce-Higgins et al.
2009), thus appropriate buffers should be applied to habitat supporting
The collection of data detailing the delicate interactions between
landscape and fauna is integral to the developer's understanding of the impact
of any changes that the wind farm development will impose on the environment—no
matter how minuscule the developer may perceive these changes to be. BWTAG
While intensive surveys to inform potential impacts are
expensive, [BWTAG] agrees that a balance must be met to obtain robust,
scientifically backed assessments of impacts. However, in the absence of data,
the precautionary principle should be applied.
National Wind Farm Guidelines
The previous section has highlighted the real risks posed to fauna,
particularly to avifauna, by the development and operation of wind farms. The
committee has received evidence detailing considerable inconsistencies in the
conduct of environmental assessments leading to insufficient and incomplete
In its interim report, the committee has recommended that the
Commonwealth Government implement National Wind Farm Guidelines to provide a
'consistent, transparent and sustainable regulatory framework for the
development, monitoring and compliance of wind farms'. These would establish
minimum standards on a range of planning and development issues including on
standards relating to avifauna.
Mr Richard Sharp noted that many of these inconsistencies exist between
state and national recovery plans resulting in the arbitrary inclusion or
exclusion of certain species from environmental assessments:
I am of the opinion that there is scope to provide better
information concerning the effect that wind towers have on fauna, especially
birds or reptiles. For example, the national recovery plan for the Superb
Parrot does not identify wind towers as a threat and yet wind farm developers
are often required to consider this threatened bird species during their design
and planning phases. Another example, concerns the White-breasted Sea Eagle. In
Tasmania, the effect of wind towers on this large bird of prey is identified in
the state recovery plan which highlights this particular species is at threat
due to the high incidence of and potential for fatalities and injuries from
collisions with wind towers. Given that the White-breasted Sea Eagle is a
nationally protected migratory species that inhabits the coastline and inland
Australia, it is disappointing that wind farm developments on the mainland do
not, as a mandatory requirement, give due consideration to the White-breasted
In addition, when certain species are included there does not seem to be
a standardised approach to the planning and conduct of fauna surveys.
Even if the department guidelines for buffering brolga
habitat areas from wind turbines were the best guidelines in the world, without
any requirement for proponents to use complete datasets of known brolga
breeding, flocking and feeding sites they are useless. We have seen that time
and time again. This systematic underestimation of both the number of brolga in
a given area and the number of flights taken can only lead to the demise of the
brolga. In addition, no cumulative studies have been undertaken. Each wind
energy facility has its own dataset and, even if the same consultants do the
research for multiple wind energy facility proposals, the data cannot be shared
due to commercial-in-confidence issues.
The committee highlights the considerable work already undertaken in
establishing the Draft National Guidelines that were released in 2010. Chapter
3 of this report has highlighted the history of this process and how these
national guidelines may be developed in a more holistic sense to capture all
aspects of the planning and development process.
These Draft National Guidelines represent an appropriate start from
which to continue the development of a new set of National Wind Farm Guidelines.
The committee notes the following key concepts from the Draft National Guidelines
that should be considered as 'guiding principles' in developing the new
National Wind Farm Guidelines as they relate to assessments of fauna:
That wind farms 'not be approved in or near areas of significant
wildlife habitat, breeding grounds, or transitory pathways'.
That 'locating additional wind turbines along a migratory
corridor may have a cumulative impact on birds and bats. This is particularly
an issue if there are species that utilise the wider area of the combined wind
farms. Migratory birds may fall into this category as, while they may only be
present at a site for short periods of time, they may be exposed to more wind
That wind farm development and planning adopt a 'a risk-tiered
approach, whereby assessment becomes more intense with increased potential for
There is an expectation in rural areas that changes to landscape character
and vistas will be minimal over time, largely reflecting the relatively low
development requirements of the pre-dominantly farming and grazing activities
of those areas. Landscapes in these rural areas are dominated by natural vistas
such as forests and grasslands with occasional farming related infrastructure
such as houses, sheds, livestock handling facilities and silos—all usually the
equivalent of one storey—interspersed in a sympathetic manner with the
landscape. The proposed development and operation of wind farms in these
settings fundamentally alters the character of these landscapes.
The committee has received considerable evidence detailing the impacts
that wind farm development and operation have on the visual amenity of their
Greg and Michelle Noel summarised the views of many submitters:
Visual amenity will be hard to get used to as the turbines
will disrupt the natural landscape qualities that we enjoy every day in this
area. We built our house in a position where we could enjoy such views and now
will be looking at it with turbines jutting out in the range beyond it.
In his submission, Mr Keith Staff noted his concerns about the primary
methodology used to illustrate to the community what a wind farm will look
These visual photomontages are displayed at public
information days in an attempt to try to prove how little impact there will be
on visual amenity for landholders and local communities or impacts on the
Landscape and hide how dominant turbines will be when located close to
properties and communities...
The outcomes are that communities have little idea of the
size/ impacts until the massive wind towers are constructed, it is then too
late for any objections.
In this context, the committee draws attention to a submission from Mr
Robert Allen in which he notes incorrect information distributed by the
proponent of Sapphire wind farm in northern New South Wales. The parent company
CWP Renewables has published a map of the proposed wind turbine locations in
which seven turbines are pictured. The map is reproduced in Appendix 5. Mr
Allen quite rightly expresses his annoyance and bemusement:
This is highly misleading as there are actually one hundred
and fifty nine turbines. And note that the map reads: The wind turbines
depicted on this map represent the approximate extent of the current windfarm
layout. That's a highly interesting interpretation of the word approximate!
Since when is 7 an approximation of 159?
In addition to the loss of views from a family home, there are tangible
impacts for those seeking to sell their house and land. Some submitters spoke
about the erosion of property values with some landholders reporting decreases
of up to 40 per cent in land value due to the immediate proximity of
a wind farm.
Mr Charles Barber and others have told the committee that 'it has rendered my
One of the many concerns that the committee has around environmental
assessments for wind farms is the poor engagement of proponents with community
groups and affected landholders on the adequacy of surveys and reports. It is
common for proponents to make no attempt to assuage the concerns of these
groups by stonewalling any opposition and ring-fencing environmental reports.
This attitude is clearly inadequate. In many cases, additional survey work and
provision of more detailed data-sets may provide comfort to the broader
community that these projects are proceeding on the basis of sound science and
the best available information. It is the committee's view that the
establishment and implementation of National Wind Farm Guidelines will assist
in maintaining coherent national minimum standards for environmental assessment
(including visual amenity) that landholders, communities, government and wind
farm operators can have confidence in.
The National Airports Safeguarding Framework note that 'wind farms can
be hazardous to aviation as they are tall structures with the potential to come
into conflict with low flying aircraft'.
The Draft National Wind Farm Development Guidelines of 2010 also note that
'wind farms inherently involve the construction of tall structures (towers plus
blades) that have the potential to impact on the safety of low flying
commercial, private and defence aircraft'. The guidelines continue:
In this respect, wind farms are similar to tall buildings,
communications towers and other tall engineered structures. They differ by
virtue that they are generally located in areas remote from other tall
structures, and are generally deployed along ridgelines (further exacerbating
the potential impacts) and they involve components moving through shared
airspace. Thus, the primary impact of a wind farm is the potential safety risk
it may pose to aircraft operating at low levels (below 350 metres above ground
level) in vicinity of a wind farm.
The Aerial Agricultural Association of Australia (AAAA), the peak body
for Australia's agricultural and firefighting pilots 'believes that windfarm
developments and especially wind monitoring towers are posing an unacceptable
threat to aviation safety and especially aerial application'.
The AAAA also notes the economic threats that wind farms pose to the aerial
applicator industry and the farming sector more broadly:
They also pose an economic threat to the industry where the
costs of windfarm development—including those of compensation for loss of
income—are externalized onto other sectors such as aerial application.
Clearly these structures will impact on the operations of aircraft
involved in aerial firefighting and aerial crop management (application of
fertilisers and pesticides) with these activities commonly being undertaken in
The Civil Aviation Safety Authority (CASA) provided evidence to the
committee about the limited role it plays in regulating airspace around wind
We know our responsibilities and the power of our
legislation, which is very limited. For the most part, wind turbines are built
away from aerodromes and certainly away from federally leased aerodromes. So
the only power that we have is to make a recommendation to the planning
authority about whether the turbine is going to be an obstacle and, if we
decide it is an obstacle, we can make a recommendation as to whether it should
be lighted and marked. That is the extent of our power.
The Crookwell Aerodrome in southern NSW—where a proponent was seeking to
develop a wind farm in proximity to the aerodrome—was discussed at the Canberra
hearing. Prior to construction of the adjacent wind farm, representations from
the AAAA led to CASA recommending an exclusion zone around the aerodrome of
3 600 metres. In this case, 11 wind turbines were not constructed in order
to comply with the exclusion zone.
This appears to be the extent of CASA's involvement in regulating airspace near
Mr Terry Farquharson of CASA told the committee that 'there are some
indications of people who might be close to below the level of the turbines
suffering or experiencing some degree of turbulence'. Further to this CASA
officials admitted that more research need to be conducted in this area;
however, CASA noted that they were currently not resourced to undertake this
'tricky and expensive' research.
Turbulence will be discussed in more detail in the crop management section.
The next section will examine specific issues relevant to firefighting
and crop aircraft.
Some submitters expressed concerns about wind turbines posing an
'increased bush fire risk' and 'decreasing the capacity of fire services to
fight bush fires'.
There is no question that aircraft play a key role in the mitigation and
control of bushfire events across Australia.
The use of aircraft plays an integral role in current
[A]erial water bombing has proved to be an integral part of
rapid fire control because the aeroplane can get access to the head of the fire
where no ground rig can go.
However, the committee received a range of evidence relating to the
extent to which wind turbines affect firefighting. The NSW Rural Fire Service
(NSW RFS) noted that:
Aerial firefighting suppression in close proximity to wind
turbines may be inhibited at times, given that the aircraft operate under the
[CASA] Visual Flight Rules for navigation by visual reference Pilots are
necessarily required to maintain standard distances from wind turbines, as is
the case with any other potential hazard such as power lines, transmission
towers, mountains and valleys...
This [NSW RFS] position paper concluded that wind turbines
are not expected to pose increased risks due to wind turbulence or the moving
Mr Craig Brownlie, an Operations Officer with the Victorian Country Fire
Authority gave similar evidence to the committee during the Portland hearing.
Mr Brownlie acknowledged that wind turbines pose a threat as obstacles to
aircraft in the same way that other anthropogenic structures do:
Operations Officer Wayne Rigg is the CFA manager for the
aerial work that we do. Basically, the air fleet that we use operates under
visual flight rules. That means that they will not operate in low light or
after light, or through cloud or smoke. Wayne has indicated that there are a
lot of other, higher-risk areas, like power lines and the like, over wind
towers. They are quite visible and they do not cause the aircraft any concern
in aviation operations for CFA.
The South Australian Government also agreed:
Where vertical obstructions exist in the airspace around a
fire such as power lines, weather masts, radio and television transmission towers,
tall trees and wind turbines, a dynamic risk assessment is undertaken prior to
the aircraft being committed to fire-bombing operations.
Although indirectly related to aerial firefighting, Infigen Energy
states that 'the construction of wind farms also result in all-weather tracks
being built to previously difficult to access areas, thereby improving the
ability of fire trucks to fight fires'. These tracks can act as 'fire breaks
and facilitate fire truck deployment'.
Despite this, the committee has received evidence suggesting that rural
fire services across the country have not properly considered these issues. Mr
Alan Cole noted that the catastrophic Cobbler Road bushfire in 2013 would not
have been able to be controlled if wind turbines had been installed at the top
of the range at the time of the fire:
The predominant Catastrophic Bush Fire Weather in the Yass
district is dominated by severe NW [north-west] winds. The Cobbler Road
bushfire of January 2013 burnt approximately 12,000 ha of farmland and
travelled from the eastern edge of Jugiong over the southern end of the Black
Range and into Burrinjuck Dam in an afternoon. Aerial water bombing of this
fire was critical in controlling its spread and eventually containing the fire.
Had the entire length of the Black Range been covered with wind turbines as per
Epuron’s desire and proposals these critical firefighting resources would not
have been able to be deployed to the head of this fire.
This view was concurred by the Noel family, landholders from South
A huge concern is accessibility for aerial fire fighting in
and around the turbines, a fire would travel a long way before the planes could
get near the fire creating great risk to adjoining landholders properties.
Further, Mr Cole noted that although legislation currently prevents
dwellings being built in Bushfire Prone Land, that 'no such legislation
regulates where [wind turbines] can be proposed on the same Bushfire Prone
The committee notes this legislative inconsistency.
The committee also notes that wind turbine manufacturers may have misled
the rural fire services by claiming that non-combustible oil is used in
On notice, the Victorian CFA confirmed that combustible oil is used in wind
turbines (AS1940 Combustible Class C2).
The Victorian CFA told the committee that it 'relies upon the manufacturers to
provide information and advice as to the nature of hydraulic fluids used and
In its submission, BWTAG expressed its concerns that the '[NSW] RFS
still have no protocols in relation to fighting fires from the air in and
around wind turbines'.
The committee heard evidence about the inadvertent consequences that result
from the placement of wind farms near operating aerodromes. Mr Jim Hutson notes
that 'the Crookwell Aerodrome will no longer be considered for aerial firefighting
by the NSW Rural Fire Service'. This is because the presence of the wind
turbines will limit the circling area of the main aircraft used in aerial firefighting
The committee received evidence suggesting that time-critical crop
management activities such as the aerial application of pesticides and
fertiliser are impacted by the presence of wind farms. Most wind farms are
hosted along ridgelines in areas of steep terrain with aerial application sometimes
being the only option to treat these crops and pastures.
Mr Mark McDonald, an experienced Aerial Agricultural Pilot quantified the
importance of aerial application to the agricultural and horticultural
industries immediately adjacent to the proposed Mt Emerald Wind Farm in far
Our records show that in past years nearly all of the 13,000
ha of arable land within 5km of the wind farm site has been treated either
occasionally or regularly by aircraft, including firefighting over the Lotus
Glen Correctional Centre.
Epuron, a wind farm owner and operator suggested that the impacts of
wind farms on crop management aircraft are minimal:
Aerial crop spraying has been reported to be ongoing within 1
km of the Cullerin Range Wind Farm with few impacts to aerial agricultural
Dr Kim Forde, an environmental consultant from far north Queensland
agreed noting that:
[A]erial spraying can only occur at wind speeds lower than
the minimal operating regime for the turbines.
Wind turbines do not operate below approx[imately] 10–15km/hr
and aerial spraying should not occur above these wind speeds due to the
inability to control where the chemical is targeted at higher speeds. Again,
the risk of interaction has been significantly over-blown.
Notwithstanding this, the committee received evidence suggesting that a
more complex relationship between wind farms and aircraft exists. As
acknowledged by CASA earlier in this section, wind turbines produce a wake of
'unpredicted and unpredictable turbulence'.
This turbulence presents two main risks to aerial operations:
The major concerns are, firstly, the risk to safety of flying
operations and, secondly, the risk of dispersal of chemicals as a result of
turbulence. And of course the negative economic impacts of these on the
agricultural spraying operators and on the viability of local agribusinesses
which need to use these services. Whilst the Aeronautical Impact Assessment
identifies that “wind shear, turbulence and downdrafts in the wake of the
turbine rotors” present “a critical hazard to aircraft such as agricultural
aircraft operating at low level and high weights during application of
chemicals and seeding”, and that wake effects may exist up to 5km from
turbines, it also states there will be minimal impact on aerial operations.
Mr Mark McDonald highlighted the risk that turbulence from wind turbines
may have on non-target crops and the surrounding environment:
The impact of turbulence on pilot safety is not the only
risk. Turbulence also has the potential to cause off-target spray drift. Aerial
agricultural operators have a legal responsibility to prevent spray drift onto
neighbouring crops, which are sometimes only metres away from the crops being
It is clear that if the flying conditions are not safe, then these
aerial operations should not be undertaken until such time as the conditions are
conducive to safe flying and that only then should aerial application occur.
However, the turbulence created by these wind turbines is not an intermittent
weather phenomenon, instead it occurs whenever the wind turbines operate and is
in addition to the vagaries of the weather that farmers and pilots must manage when
undertaking their aerial activities. Ultimately, in areas with wind farms the
optimum window for aerial application is shortened and the net result will be
that farmers are not able to spray their fields and manage their crops,
incurring a financial loss as a result:
Wind turbines amongst land used for intensive grains
production will irrevocably impinge upon crop management practises. Timeliness
of crop nutrition, and the application of crop protection products, is critical
in maximising productivity and profitability in agriculture. To this end,
aerial applications of fertilisers for nutrition, and herbicides, fungicides
and insecticides for crop protection and quality, are the key to efficient and
rapid management decisions as weather patterns and rainfall events unfold.
Imported pests, such as Italian snails, are contained by aerial baiting of
large areas of land when small windows of opportunity are presented for this
practice to be effective. To restrict and deny aerial access to the cropping lands
of those grain producers on whose properties wind turbines are placed, or are
adjacent to such structures, is an impost on grain production that ground based
machinery cannot compensate for.
The committee accepts that there are a range of risks inherent in the
work of pilots who conduct aerial firefighting and crop management activities.
Despite this, the committee recognises that current regulation does not provide
adequate protections for pilots operating aircraft in the vicinity of wind
turbines. In its submission, AAAA noted that the wind industry needs to be 'as
a minimum, regulated to provide a national database of tower locations for bona
fide low level aviation operators and be required to be marked in accordance
with NASAG (Department of infrastructure) guidelines'.
In addition, the committee notes the National Airports Safeguarding Framework
contains a voluntary provision for obstacle lights and a section on turbulence
'in making decisions regarding the marking and lighting of wind farms and wind
monitoring towers, wind farm operators should take into account their duty of
care to pilots and owners of low flying aircraft.'
It is the committee's view that in the interests of pilot and community safety
that these voluntary standards relating to obstacle marking are made compulsory
for all current and future wind turbines.
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