Australian Labor Party Senators' Dissenting Report
Australia's wind energy industry remains small in comparison both with
its potential size and with the total size of wind energy installed around the
world. However, to date it has played a vital role in abating the greenhouse
gas emissions of Australia's electricity generation sector and has contributed
the majority of new generation capacity under the Renewable Energy Target (RET)
The explosion of wind energy production around the world and Australia's
relatively small participation in this growth to date was well summarised in
evidence given before the committee:
Wind energy has had one of the most sustained and rapid
growth rates of any industry on the planet. According to the Global Wind Energy
Council, 15 years ago there were only 13,000 megawatts of wind energy installed
world wide. That is about three times what we have installed here, in
Australia, now. Three years later, wind generation doubled. Three years later,
it doubled again. Three years later, it doubled—again. Three years later it
doubled yet again. And three years later the exponential growth finally slowed
down to only 50 per cent, partly due to the GFC. This is phenomenal success, by
any measure. I challenge you to think of another good or service that has had
such a long-running and rapid growth rate.
Last year the entire electrical generational capacity of
Australia's national electricity market was matched around the world by the
building of new wind farms. And how is Australia doing? We have installed just
a bit over one per cent of the world's wind turbines. In fact, 14 countries
have more wind energy installed than Australia. Five countries have over five
times as much wind energy installed than we do, even though we have one of the
largest—and windiest—countries on the planet. Australia is not in any way,
shape or form the proving ground for wind energy. Wind farms have been
operating for decades overseas and the industry has been extremely successful.
Far from being a pioneer of an experimental and possibly dangerous new
technology, Australia has to date adopted a relatively limited amount of what
is a very well-established method of electricity generation around the world. Furthermore,
the Australian wind energy industry has successfully worked within some of
strictest planning controls found anywhere in the world.
Australia’s largest electricity generator, AGL, has stated that
three-quarters of Australia’s thermal plant is at the end of its useful life
and has committed to closing its own coal plants by 2050. In this context, it
is undeniable that Australia must develop public policy that will encourage the
development of low-cost, renewable energy sources to replace outdated thermal
The benefits of wind energy generation in terms of greenhouse gas
abatement are well established, as are the minimal impacts wind farms have on
their local environment. The integration of wind energy into electricity grids
has been successfully managed around the world and Australia has been no
exception in this regard. Furthermore, the wind energy industry has provided a
much-needed source of employment and income in regional communities.
Labor Senators are disappointed that recognition of the levelised costs
of different energy sources was absent from the majority report. We note that
it is well-established that wind farms have among the lowest levelised cost of
any form of new electricity generation capacity, whether it be renewable or non-renewable.
The Clean Energy Council commissioned an independent study on wind farm
investment, jobs and carbon abatement from consultants SKM in 2012. SKM looked
at existing wind farm financial data and interviewed companies with experience
in numerous wind farm projects. The report presents a breakdown of investment
during the construction and operations phases of a major wind farm, collated
from actual data provided by developers, contractors, advisers and consultants.
The report found that for every 50 megawatts of capacity, a wind farm:
has an estimated average construction workforce of 48 people with
each worker spending $25,000 per year in the local area, equating to some $1.2
million per year flowing into hotels, shops, restaurants, and other local service
employs around five staff for operations and maintenance,
equating to an ongoing local annual influx of $125,000;
provides up to $250,000 annually in payments to farmers, a
proportion of which flows into the local community; and
provides a community contribution of up to $80,000 per year for
the life of the project.
With this background in mind, Labor Senators reiterate their strong
support for the wind energy industry in Australia. The Australian Labor Party
has recently announced a strengthened commitment to renewable energy generation
in Australia by stating its intention that 50 per cent of Australia's large
scale electricity production come from renewable sources by 2030. As it
currently provides the lowest cost renewable energy source, the wind energy
industry will play a large role in meeting this target.
Labor Senators believe this inquiry has been prevented from arriving at
a balanced view of the wind industry by several factors.
First, the terms of reference for the inquiry exclude from consideration
the specific environmental benefits provided by wind energy generation and the
broader imperative of reducing the carbon intensity of the world's energy
production in order to mitigate the impact of climate change. The terms of
reference also exclude any comparison of wind energy generation with the
impacts of other forms of energy generation on human health, the local
environment and climate change. In short, the terms of reference have been
framed so as to avoid consideration of the primary issues that must be
addressed by public policy regarding Australia's energy generation mix.
Second, the terms of reference focus on a series of topics that have
been repeatedly raised by opponents of wind energy generation and found to be without
substance in numerous previous inquiries and reviews. Thus, the purported
health impacts of wind farms have again featured most prominently in this
inquiry and all expert testimony provided to the committee has again found such
claims to be without foundation, as has occurred in numerous previous
inquiries. There simply is no evidence of any causal link between the
operations of wind turbines and human health impacts.
This pattern has been repeated with regard to the following baseless
wind farms do not provide any greenhouse gas abatement;
the energy consumption of wind turbine manufacturing outweighs
their lifetime energy production;
wind farms have led, via the RET scheme, to significant cost
imposts on electricity consumers;
wind farms have an intolerable impact on the local bird and bat
wind farms present a significant fire risk and hamper the work of
wind farms present a significant threat to aviation operations.
As discussed in detail under each term of reference, Labor Senators
believe evidence presented to the inquiry convincingly refutes each of these
Response to majority report
It is pleasing to note that the majority report states that:
acknowledges the need for Australia's renewable energy sector to develop and
prosper. It also recognises that a properly regulated wind industry should be
an important part of the sector's future growth.
However, Labor Senators are extremely concerned that the recommendations
put forward in the majority report stand in direct contrast to this statement.
If enacted, they would threaten Australia’s ability to secure a low-cost, clean
energy mix into the future by making future wind farm investment unviable.
For this reason, Labor Senators strongly disagree with most of the
recommendations and findings of the committee majority.
Labor Senators were particularly disappointed that members of the committee
majority have chosen to discount the overwhelming evidence from government
bodies, both state and federal, academics, health experts, acousticians and
economists in order to recommend new and onerous regulations in the interim
The willingness of the Government to adopt these recommendations, even
before the committee provided its final report, must be seen in the light of
other recent actions it has taken to hamper the expansion of renewable energy
generation in Australia, including the repeal of an effective carbon pricing
regime, the reduction of the RET and directing the Clean Energy Finance
Corporation (CEFC) not to invest in wind and solar generation projects.
In light of the fact that there is no credible scientific evidence to
causally link wind turbines with human health impacts, Labor Senators strongly
oppose recommendations put forward by members of the committee majority that
appear to rely on such discredited claims.
Labor Senators note that the Clean Energy Council provided a strong
response to an article published in the Australian which outlined leaked
recommendations from the majority report. This response gives a clear
indication of the damage that the these recommendations would do to future
Adopting these reckless recommendations would damage
Australia’s international investment reputation, right when we are
finalising major agreements with some of our biggest trading partners,” Mr
Thornton said. Business needs stability and confidence to invest, and this has
only recently been restored to the renewable energy sector after 18 months of
Hundreds of millions of dollars’ worth of projects have been
announced since a deal on the Renewable Energy Target was legislated, and these
will create hundreds of jobs and major investment in regional and rural areas
of the country.
Adopting the headline recommendation of this report would be
economically reckless, and shows some of the senators are out of touch with the
business community and the Australian people, who overwhelmingly support
Labor Senators concur with the assessment of the Clean Energy Council.
Labor Senators believe the regulatory regime, and associated research,
that would be imposed by the majority recommendations would be enormously
expensive, duplicative and unworkable.
Proposals to significantly alter the distribution of responsibilities
between the Federal Government and the states and territories with regard to
land use planning and environment protection are also not supported by evidence
gathered by the committee. No systemic problems with the planning, monitoring
and compliance regimes governing wind farms have been identified during this
inquiry. Furthermore, no evidence was produced that would warrant the
Commonwealth imposing onerous bureaucratic measures on a single industry to the
exclusion of other comparable industries.
Thus, Labor Senators do not support the proposal to establish a
'National Wind Farm Ombudsman' or 'Wind Farm Commissioner'. This proposal
should not be proceeded with. It would constitute a misuse of resources by
replicating existing complaint‑handling mechanisms in each state and
territory and would be a considerable administrative burden for the wind energy
Labor Senators also do not support the creation of an 'Independent
Expert Scientific Committee on Industrial Sound', nor the imposition of a levy
to fund such a body. As detailed in discussion under term of reference (c), the
National Health and Medical Research Council (NHMRC) already provides advice on
this topic and has acted professionally with regard to its evaluation of the
scientific evidence in this area.
The attempt to establish a parallel scientific advisory body is simply a
means to sidestep the findings of the NHMRC, which are inconvenient for those
who wish to assert such a link between human health effects and wind farms.
Labor Senators believe this dismissive attitude to scientific evidence and to
the work of the NHMRC represents a highly irresponsible approach to setting
public health protection measures.
Labor Senators do not support the establishment of a 'National
Environment Protection (Wind Turbine Infrasound and Low Frequency Noise)
Measure'. The committee has been presented with no scientific evidence to
support the claim that infrasound at the sound pressure levels generated by
wind turbines is harmful to human health. Evidence provided to the committee
suggests that there is no precedent anywhere in the world for using infrasound
as part of a noise regulation regime for wind farms.
Labor Senators strongly disagree with any recommendation that undermines
the bipartisan agreement made in 2015 regarding the Renewable Energy Target. We
are particularly concerned with the concept of using the Emissions Reductions
Fund as a substitute mechanism for supporting renewables projects.
The renewables industry has been in limbo for 18 months as a result of
the government’s failure to keep its election promise that there would be no
changes to the Renewable Energy Target. Investment has just started again after
bipartisan agreement was reached on a 33,000 GWh target by 2020. Proposing
further amendments at this point in time is extremely short-sighted and will be
seriously damaging to investor confidence.
This recommendation would not only see the death of renewables
investment in Australia, along with thousands of jobs in regional communities,
but it would put a massive impost on the Federal Budget, as the Emissions
Reductions Fund is a direct taxpayer-funded subsidy.
This recommendation fundamentally misunderstands the intent of the
renewable energy target, which has the dual goals of reducing carbon emissions
and providing a catalyst for the transition of Australia towards a future
low-carbon energy mix.
The Emissions Reduction Fund is an inefficient, expensive waste of
taxpayers' money that will not achieve meaningful emissions reductions.
In contrast, the government’s own Renewable Energy Target review
concurred with the majority of modelling that the Renewable Energy Target will
actually lead to lower electricity bills for consumers from 2020. This is discussed
in detail in Section (a).
To switch renewable energy support from an efficient market mechanism to
an inefficient taxpayer-funded subsidy would be both expensive and destructive.
Labor Senators note that this recommendation also seeks to misrepresent
the realities of life-cycle emissions from wind farms. The majority report has
ignored the advice of turbine manufacturers and government agencies that wind
turbines generally repay the costs of energy expended within three to seven
months of operation, as discussed in detail under term of reference (h).
The recommendation also falsely implicates renewable energy in the
levels of back up energy generation in Australia. It is unfortunate that the majority
report privileges the opinion of Alan Moran over the advice of the national
grid operator, the Australian Energy Market Operator, which has refuted claims
that the introduction of greater levels of wind has required an increase in
capacity dedicated to maintaining the stability of the grid. This is also discussed
in detail under term of reference (h).
Labor Senators are also concerned by the fallback recommendation to make
Renewable Energy Certificates expire in five years. This would make wind farm
investment completely unviable and almost certainly guarantee that no new wind
energy would be installed in Australia. We also hold concerns that this
recommendation would push up electricity prices for consumers by removing the
downward pressure on wholesale prices provided by renewable generation
supported by the RET.
Labor Senators believe the recommendation to compel State Governments to
comply with National Wind Farm Guidelines and the NEPM by linking compliance to
the issuance of Renewable Energy Certificates is extremely heavy-handed and
shows little understanding of the distinction between state and federal
Labor also notes the suggestion that there should be ‘general
compliance’ with National Wind Farm Guidelines, but ‘specific compliance’ with
the NEPM without providing any definition as to what constitutes ‘general’ or
‘specific’ in this context.
Labor Senators do not support the recommendation for the
Productivity Commission to undertake research into the impact of wind power
electricity generation on retail electricity prices. This recommendation would
constitute a misuse of resources as the government’s own Renewable Energy
Target Review and independent modelling has found that renewable energy puts
downward pressure on wholesale electricity prices and the RET leads to lower
electricity prices for consumers. This is discussed in detail in Section (a).
Labor Senators note that the majority report recommendation for a
performance audit of the Clean Energy Regulator fundamentally misunderstands
the mandate and duties of this body and seeks inquiry into areas that are
completely outside the remit of the CER. The CER’s remit and performance is
discussed in detail in Section (b).
Labor Senators are highly doubtful that the states will decide to
participate in the onerous regime proposed in the report and believe the
recommendation of a federal takeover in the event of non-cooperation is
completely inappropriate and unrealistic and would present a massive cost
burden to the Federal Budget.
Dissenting report recommendations
Labor Senators recommend that the Federal Government not proceed
with the recommendations made to it in the majority report.
Labor Senators further recommend that the Federal Government reassure
the wind energy industry, which is both an important source of income and
employment in rural areas and a vital means of abating Australia's greenhouse
gas emissions, that it is not intent on preventing its further development
based on unsubstantiated claims of negative health, environment and economic
Labor Senators recommend that the Federal Government publicly
wind farms are an important means of reducing greenhouse gas
emissions from Australia’s electricity sector, thereby contributing to our
greenhouse gas emissions reduction goals;
the health impacts of fossil fuel extraction and generation are
acknowledged by the medical and scientific community;
there are no causal links between wind turbines and impacts on
the wind industry is a growing industry at a time when
Australia’s manufacturing sector is undergoing significant change and
downsizing and that it provides valuable employment opportunities in regional
the continued growth of the renewable energy industry, including
wind, is a positive thing for Australia’s economy and its environment.
Although no systemic failings with the current regime governing wind
farm developments were identified in the inquiry, Labor Senators believe that
discussion on the following topics highlighted some areas where improvements
can be made.
As discussed in detail under term of reference (d), the committee
received evidence that the distribution of planning, monitoring and compliance
responsibilities between state and local governments is a point of tension.
Specifically, some local government bodies explained that the complex and
technical nature of wind farm planning approvals and compliance work are beyond
their expertise and resourcing.
Labor Senators note that several states have moved to centralise
planning approvals for wind farms at the state level to address this problem.
While this may lessen the burden that falls on local governments, the task of
conducting compliance work will still require significant resourcing.
While noting that the best distribution of resources and
responsibilities is a matter for determination by each state jurisdiction,
Labor Senators believe local governments should be sufficiently resourced to
effectively meet their responsibilities.
Labor Senators recommend that state governments ensure that local
governments are adequately resourced to undertake their monitoring and
compliance roles under state planning laws.
As also discussed under term of reference (d), Labor Senators note that
the Clean Energy Council has developed, with the support of a range of wind
energy companies, the Community Engagement Guidelines for the Australian
Wind Industry. This document was developed by the Australian Centre for
Corporate Social Responsibility and, given the vital role effective community
engagement plays in successful wind farm developments, Labor Senators believe the
best-practice recommendations it contains could be given a more formal status.
Labor Senators recommend that state and territory governments
consider the codification of community engagement guidelines based on the Clean
Energy Council's Community Engagement Guidelines for the Australian Wind
Industry to ensure a greater level of community confidence and input is
generated by wind farm planning, construction and operation.
As discussed under term of reference (e), Labor Senators note that post‑construction
noise monitoring is generally conducted by acoustic consultants retained by
wind farm developers. Labor Senators do not question the professionalism of
these acoustic consultants and believe evidence provided to the committee
supports the view that this arrangement has not affected their independence or
the nature of their advice.
However, Labor Senators believe
that the community's perception of independence might be enhanced if this
arrangement were reformed to implement an 'arm's length' relationship with
Labor Senators recommend that state and territory government
consider reforming the current system whereby wind farm developers directly
retain acoustic consultants to provide advice on post-construction compliance.
the effect on household power prices, particularly households which
receive no benefit from rooftop solar panels, and the merits of consumer
subsidies for operators
Before addressing the effect of the RET scheme on household power
prices, Labor Senators emphasise that, contrary to repeated assertions made
during the inquiry, the scheme does not involve any taxpayer subsidy of
renewable power generation. The scheme does not impose any costs on the federal
budget beyond the administrative costs of the Clean Energy Regulator (CER).
As explained by the CER, the RET scheme works by creating a market for
renewable energy certificates which must be purchased and surrendered by
electricity retailers, not by funding from the federal budget:
The Renewable Energy Target works by allowing both
large-scale power stations and the owners of small-scale systems to create
certificates for every megawatt hour of power they generate. Certificates are
then purchased by electricity retailers who sell the electricity to householders
and businesses. These electricity retailers also have legal obligations under
the Renewable Energy Target to surrender certificates to the Clean Energy
Regulator, in percentages set by regulation each year. This creates a market
which provides financial incentives to both large-scale renewable energy power
stations and the owners of small-scale renewable energy systems.
The Chief Executive Officer of the CER, Ms Chloe Munro, emphasised this
point when she appeared before the committee:
There is no taxpayer funding of
the renewable energy targets. The way that it operates is that certificates are
created on the one hand and purchased and surrendered on the other hand
entirely within the electricity market. So the payment for those certificates
is made essentially by electricity retailers
This is not a tax and does not involve a subsidy from the federal
government to clean energy generators. As discussed further below, while the
cost of the scheme is passed on to consumers by electricity retailers, this direct
cost is offset by the downward pressure on wholesale prices that is also a
result of the scheme.
When evaluating the impact of wind generation on household electricity
prices, it is important to note that the expansion of renewable generation
capacity under the RET affects power prices in two opposing ways. The overall
effect on household electricity prices depends on which of these two opposed
effects are stronger. These price pressures are described briefly below.
As explained by the Department of the Environment, wind power, once
installed, has lower operating costs than fossil fuel competitors because it
can operate at around zero marginal cost—that is, it does not have any ongoing
fuel costs. As a result:
Wind farms are able to bid their
capacity into the National Electricity Market at relatively low prices to
ensure their generation is dispatched. By displacing gas or coal generation,
wind power places downward pressure on wholesale electricity prices in the
short to medium term. To the extent these lower prices are passed on to homes
and businesses through competitive tension, wind power can lead to lower power
costs for consumers.
To the extent that the policy
initiatives stimulate an excess of new wind generation beyond that required by
the market, the downward pressure on wholesale prices can be amplified.
The countervailing price effect arises from the RET and other
cross-subsidy schemes, which aim to overcome the fact that wind farms have
relatively high capital costs such that they are not yet commercially viable
without support. The RET 'enables new renewable energy projects, including wind
farms, to earn additional revenue through the creation and sale of tradeable
certificates for renewable generation. The Renewable Energy Target Rules oblige
electricity retailers to purchase and surrender these certificates, the costs
of which are passed on to electricity users.'
As calculated by the Australian Energy Market Commission, the cost of
the RET cross subsidy has been estimated to make up a small proportion of
retail electricity bills at approximately four per cent.
As wind makes up approximately half of renewable generation under the RET, it
follows that the cross subsidy specifically directed to wind power makes up
approximately two per cent of household bills.
This impact is, however, offset by the impact of increasing renewable
generation on wholesale prices.
To determine the impact of downward pressure on wholesale electricity
prices, modelling has been undertaken by a number of organisations. The
majority of this modelling concurs that, in the long term, the downward
pressure on wholesale electricity prices will outweigh the increased costs from
the RET cross subsidy, leaving consumers better off than they would be in the
absence of the RET.
Modelling undertaken by ACIL Allen for the recent Warburton Review,
which was undertaken prior to the recent reduction of the RET, confirmed this
conclusion. The Department of the Environment summarised their findings as
...the ACIL Allen modelling
indicates that while the currently legislated Renewable Energy Target would
cumulatively add around $250 in net present value terms to average household
electricity bills over the period 2015 to 2020, this cumulative impact would
fall virtually to zero by 2030 as the downward pressure on wholesale
electricity prices comes to outweigh the certificate cost impost after 2020.
While the cumulative cost over the five years between 2015 and 2020 has
been estimated at $250, the Climate Institute has noted that this amounts to an
impost of approximately $1 per week for the average household and, as noted
above, lower wholesale prices are projected to offset this amount by 2020.
Labor Senators therefore emphasise that the RET has delivered a
substantial boost in renewable energy generation in Australia, with attendant
greenhouse gas emissions abatement, without a significant increase in retail
costs over the longer term.
Labor Senators also note that recent modelling by a variety of firms has
also found that removing or substantially reducing the RET would cost more
money than it saves.
One example of such modelling is that developed by Schneider Electric for their
client group of large energy consumers. Schneider Electric informed the
committee that their research suggested the Large-scale Renewable Energy Target
(LRET) would have three benefits:
Firstly, we found that the LRET
would act as a hedge against increasing natural gas prices. The LRET directly
influences the generation mix and, by reducing the reliance on gas-fired
generation, the LRET reduces the sensitivity of the electricity markets to gas
prices. The LRET therefore acts as a hedge against rising gas prices, which are
expected to increase in the long term, due to linkage of the Australian east coast
gas market to the global markets via the exporting of LNG and growing global
and domestic gas demand. Secondly, we found that the LRET acted as a hedge
against carbon emissions, and may keep carbon emissions lower in the longer
term. By reducing carbon emissions, the LRET reduces exposure to the market—and
our customers—to carbon costs, acting as a potential hedge against rising taxes
or permit prices into the future. In addition, the low-emission volumes under
the RET may also help keep carbon prices lower.
Finally, and most importantly for
our customers, we found the impact of the LRET was on the long-term wholesale
price. The LRET is forecast to result in a generation mix with lower marginal
cost, lower carbon emissions and increased competition in the wholesale
electricity market, all which serve to reduce prices. The scenarios
investigated under the RET in its current form result in lower wholesale
electricity prices than the scenarios of a reduced version of the RET or the
repeal of the RET.
The Clean Energy Council submitted the following estimated costs to
households of the abolition of the RET:
Analysis by the CEC using the
results of the Review Panel’s modelling has shown that by early 2020 the
average household power bill would be an estimated $35 a year higher if the
target is repealed compared to leaving it unchanged. By 2030 prices are
expected to be more than $70 a year higher under a Repeal scenario on average.
The committee was presented with evidence from Frontier Economics,
stating that its modelling of the RET had found that the downward pressure on
wholesale prices may not in fact be sufficient to fully counteract the direct
cost to consumers:
Our modelling has tended to show that that target
would lead to higher retail prices than the reduced target. Our submission
pointed to that acknowledgement from another economic consulting firm, Roam
Consulting, which said that this merit order effect or the suppressing of
wholesale prices is likely to be transient and models may overstate this effect.
Labor Senators note that this finding is contradicted by modelling
undertaken by a number of other organisations, as discussed above, and that
conclusions as to the balance of these price effects is highly dependent on
assumptions. In this regard, Labor Senators note criticisms that have been made
in the past about assumptions used by Frontier Economics in its modelling,
particularly with regard to the cost of renewable generation projects, the cost
of fossil fuels for other forms of generation, and the ability of industry to
meet the RET.
In light of these findings, Labor Senators believe there is no case for
the further reduction or abolition of the RET based on its impact on household
Labor Senators emphasise that the recent reduction of the RET to 33,000
GWh by 2020, brought about by the passage of the Renewable Energy (Electricity)
Amendment Bill 2015 on 23 June 2015, was agreed to with great reluctance by the
Labor Party. Prior to this compromise being reached, the uncertainty over the
future of RET had effectively halted new investment in the industry and placed
at risk its future viability, a situation which the Labor Party could not allow
At the time this compromise position was reached, the Labor Party made
it clear that it viewed this reduced target as a floor on which to build,
rather than a ceiling. It has since announced its support for a more ambitious
target of sourcing at least 50 per cent of Australia's large scale generation
from renewables by 2030.
Labor Senators note evidence from the CER that it has accredited 440
power stations under the LRET and that this includes 82 wind farms with a
combined installed capacity of around 4,100 MW.
The recent growth in wind generation means that it now accounts for 60 per cent
of Large-scale Generation Certificates (LGCs) created by power stations
Wind accounts for the majority of LGCs currently produced because 'the
levelised cost of energy from wind is cheaper than other renewable sources.'
The 2012 Australian Energy Technology Assessment report of the
Bureau of Resources and Energy Economics, Australian Energy Technology
Assessment table over the page shows that wind is a cheaper source of energy
than coal and renewables such as solar and geothermal.
costs of energy in 2012 Australian dollars
AETA (excl CO2
Energy Agency (A$/MWh)
coal with CCS
pulverised black coal
cycle gas turbine
cycle gas turbine with carbon capture and storage
– non tracking
Source: Bureau of Resources
and Energy Economics, Australian Energy Technology Assessment, 2012, p.
The Bureau of Resources and Energy Economics estimates that by 2030,
solar photovoltaic and wind are expected to have the lowest LCOE of all of the
Wind-generated, onshore electrical power has low long-term marginal power
generation costs because:
the fuel source is renewable, sustainable and free, but the
resource itself is area-specific, and also variable;
the power generation does not produce polluting gases and
emissions, which need to be mitigated and/or incorporated into the full costs
of electricity generation; and
it has no water usage.
The Australian Energy Market Operator (AEMO) also provided the committee
with tables comparing the levelised cost of generation options for renewable
and non-renewable technologies (Table 2). These figures illustrate that wind
power remains the most competitive form of renewable generation and with solar
being the second most competitive.
2—LCOE across renewables technologies
Suggestions were put forward during the committee's inquiry that a
proportion of LGCs ought to be reserved for particular technologies, such as
solar. Labor Senators do not agree with such proposals as reserving a
proportion of the LGCs for renewable technologies with higher levelised costs
will reduce the efficiency of the RET in terms its cost per unit of greenhouse
gas abatement. Furthermore, the costs of various forms of renewable generation
are changing as technology advances, and the RET should remain technology
neutral so as to allow the most efficient forms of investment to take place.
Labor Senators note that the Government has recently demonstrated a
similar determination to direct investment to less commercially viable forms of
generation by apparently ordering the CEFC not to invest in wind generation
projects or in household and small-scale solar projects.
These directives come after an earlier directive to the CEFC to generate a
significantly higher investment return over the medium term without increasing
its level of portfolio risk. The Chair of the CEFC stated in response to this
Within the narrow field of
investment allowable under the CEFC Act, achieving such increased returns
without increasing risk, is highly challenging, and in my experience, outside
the scope of normal market opportunities. In this respect, the 2015 Investment
Mandate requires the CEFC to seek out additional investments that are outside
market norms, in addition to carrying on its existing investment activities.
These events highlight the Government's disregard for commercial
realities of investment in renewable energy generation and its intention to
stymie the CEFC in its mandated task of facilitating financing for clean energy
projects. Labor Senators emphasise that the CEFC has been highly successful to
date and, far from imposing a burden on the federal budget, has delivered a
rate of return on its investments of 3.5 per cent above the benchmark return of
the Government five-year bond rate.
how effective the Clean Energy Regulator is in performing its
legislative responsibilities and whether there is a need to broaden those
Any judgements regarding the effectiveness of the CER must be based on a
sound understanding of its mandate. Labor Senators note that the committee
received a number of submissions that questioned the effectiveness of the CER,
but in most cases these submissions appeared confused about its
The CER is an independent statutory authority established by the Clean
Energy Regulator Act 2011. It administers a number of clean energy schemes,
but it is the RET scheme, more specifically the LRET component, that is
relevant to this inquiry. The RET is administered in accordance with the Renewable
Energy (Electricity) Act 2000.
As summarised by the Department of the Environment, the responsibilities
of the CER in relation to wind farms are limited to 'managing the tradable
certificate markets established under the scheme legislation', which includes
the following activities:
Accrediting eligible renewable energy power stations under the
Renewable Energy Target scheme;
Managing the online Renewable Energy Certificate Registry
(including the issue, transfer and surrender of certificates);
Maintaining registers of accredited power stations, large-scale
generation certificates and applications for accredited power stations: and
Monitoring and enforcing compliance by certificate market
participants with the Renewable Energy Act and regulations.
It is important to note that the CER is not responsible for:
matters relating to wind farm
siting (planning and approval processes) and operation (including health and
safety impacts) of wind farms. Under Australia's constitutional arrangements,
these matters are properly the responsibility of the states and territories.
The Regulator is required to take account of compliance with the relevant laws
of the states and territories.
The CER noted in its submission that the RET has been the subject of
three reviews in the last four years, twice by the Climate Change Authority in
2012 and 2014, and most recently in the Warburton RET Review.
The Warburton review commented specifically on the administration of the RET by
the CER, but did not adopt any suggestions for improvements:
The Panel has investigated
opportunities to reduce administration and compliance costs of the RET scheme
while allowing it to meet its objectives. The majority of the submissions to
the review indicate satisfaction with the administration of the scheme with
only a few proposals for improving administrative arrangements.
With regard to these reviews, the Department of the Environment also
...none these has included findings that would cast doubt on
the Regulator's effectiveness in performing its legislative responsibilities or
recommendations to broaden the Regulator's responsibilities in relation to wind
farms. In relation to the latter, steps in that direction could run the risk of
exceeding the Commonwealth's constitutional jurisdiction, duplicating state and
territory regulations and creating additional costs for business that are
difficult to justify.
The division of responsibilities between the states and territories and
the Commonwealth with regard to regulation of wind farms is discussed further
under terms of reference (d) and (e).
The role of the CER in accrediting power stations to participate in the
LRET attracted considerable comment during the inquiry. The CER emphasised that
the accreditation process is only for the purpose of allowing participation in
the LRET, not for the purpose of 'certifying that the relevant power station
has met State or Territory environmental, planning or work health and safety
approvals and requirements.'
LRET accreditation is dependent on the power station generating some or
all of its power from an eligible energy source and on the power station
meeting the following prescribed requirements set out in subregulation 4(1) of
the Renewable Energy (Electricity) Regulations 2001:
- a power station that is in the
national electricity market must use NEM standard metering; and
a power station that is not in the
national electricity market must use metering that enables the Regulator to
determine the amount of electricity generated by the power station; and
the power station must be operated
in accordance with any relevant Commonwealth, State, Territory or local
government planning and approval requirements.
Some witnesses suggested that the CER has failed to act on evidence that
power stations are breaching the requirement that power stations 'must be
operated in accordance with any relevant Commonwealth, State, Territory or
local government planning and approval requirements'.
The CER explained that it requires power stations to regularly declare
that they are in compliance with all laws and it also follows up with state,
territory or local authorities when it becomes aware of suggestions that power
stations are not in compliance.
However, the CER cannot act to suspend the accreditation of a power
station merely on the suspicion that it is not meeting requirements under state
and territory law. It is not an appropriate body to adjudicate on whether a
power station meets state or territory planning requirements. Rather, it must
wait for objective evidence that such a breach is occurring, which would
generally be a state or territory planning body or court making a definitive
finding to that effect.
The CER's General Counsel, Mr Purvis-Smith, noted that the power to
suspend the accreditation of a power station under the LRET had not been
exercised to date. He explained that this is because definitive findings had
not been arrived at by state and territory authorities:
The process works. The difficulty is that we rely on that
objective evidence. In doing that, we rely on the states and territories to a
large degree to form a view as to whether a contravention has occurred. It is
state based law. These are approvals that have been put in place by state and
local authorities. Of course, we are going to listen to what they have to say.
We have not been in the situation where a state or territory has made a
definitive finding that there has been a breach of their local laws. There has
been conjecture but no-one, to my knowledge, has ever moved to a final
declaration finding, court proceeding, to say there has been a contravention of
We do not necessarily have to wait for the states and
territories to find a contravention. If there was an admission of a breach,
that would be sufficient. It is not a closed inquiry, in that sense. We are
open to other avenues of finding out that information.
Labor Senators believe that, with regard to its administration of the
LRET, the CER has effectively fulfilled its legislated responsibilities to
date. Suggestions that the CER has failed to properly address concerns about
the planning compliance of certain wind farms are founded on the mistaken
belief that the CER is in a position to override or prejudge planning
determinations at the state and territory and local government levels.
Labor Senators do not agree with suggestions raised during the inquiry
that the remit of the CER should be increased such that it would have a direct
role in evaluating the compliance of power stations with state and territory
regulations or in monitoring the sound levels of power stations.
The CER, which is an economic regulator with a very specific mandate,
does not possess the expertise to properly address such matters. Even if it
were possible to acquire such expertise, a highly undesirable situation would
emerge in which the CER would be attempting to determine compliance with state
and territory based planning laws in parallel with state and territory planning
bodies or, alternatively, attempting to determine compliance with an as yet
non-existent Commonwealth planning regime governing wind farms.
Labor Senators therefore do not believe there is any justification for
broadening the remit of the CER in an attempt to address perceived failings of
state and territory based planning regimes. State and territory planning
decisions governing all types of development are inevitably subject to
controversy from time to time. No case has been made as to why wind farm
developments require the specific intervention of the Commonwealth.
This position is consistent with that of the CER itself:
It is the respectful submission of the Regulator that its
responsibilities do not need to be broadened. The Clean Energy Regulator is an
economic regulator, charged with the responsibility of ensuring that the RET
scheme is administered appropriately. The Clean Energy Regulator does not have,
and should not have, responsibility for matters that are currently within the
remit of the relevant State or Territory authorities (for example planning
approvals, work health and safety obligations and environmental protection).
Finally, Labor Senators note that many submissions that were critical of
the performance of the CER focussed on the claim that LGCs have been invalidly
issued because greenhouse gas emissions reductions are not in proportion to the
amount of renewable electricity generated by certified power stations. These
criticisms are also founded on a misconception of the RET as LGCs are issued on
the basis of eligible electricity generated, not on the basis of emissions
reductions. This matter is discussed further below under term of reference (h).
the role and capacity of the National Health and Medical Research
Council in providing guidance to state and territory authorities
Labor Senators note that the committee received a number of submissions
and also took evidence at public hearings from people who attribute a wide
variety of health symptoms to the operation of wind farms and put forward a
number of mechanisms by which these effects are supposed to have been induced,
including by exposure to infrasound.
Labor Senators do not question that these submitters and witnesses have
experienced such symptoms. However, Labor Senators also emphasise that the
suggestion that these symptoms have been directly caused by wind farms is
entirely without scientific basis. No credible evidence has been presented to
this inquiry to establish such a direct causal link.
Labor Senators note that the committee majority report states:
...it would seem that the NMHRC's assessment of the lack of
consistent evidence coexists with significant empirical, biological and
anecdotal evidence that many people living nearby wind turbines suffer similar
symptoms and identify the wind turbines as the cause for their symptoms.
Labor Senators do not accept this characterisation of the evidence put
before the committee. While the committee heard a large amount of anecdotal
evidence regarding the supposed health impacts of wind turbines, it did not in
fact receive any empirical or biological evidence to this effect.
Labor Senators emphasise that the confusion of anecdote with reliable empirical
evidence is characteristic of the irresponsible approach taken by majority
senators in this inquiry.
The NHMRC is 'Australia's leading body for supporting health and medical
research, developing evidence-based health advice, and setting standards in
ethics in health care and research, within a single national organisation.'
In the opinion of Labor Senators, it is the appropriate body to assess and
report on the evidence regarding health effects of wind farms.
The NHMRC is established as an independent statutory body under the National
Health and Medical Research Council Act 1992 and comprises the CEO, the
council, and its principle committees. The council is itself made up of state
and territory chief health or medical officers, the Chief Medical Officer of
the Australian Government and a range of health and medical research experts.
Under section 7(1)(a) of this act, the NHMRC is required to inquire
into, issue guidelines on, and advise the community on matters relating to:
improvement of health; and
- the prevention,
diagnosis and treatment of disease; and
- the provision of health care; and
- public health research and medical
- ethical issues
relating to health;
Under section 7(1)(b), the NHMRC is also required to advise and make
recommendations to the Commonwealth, states and territories on these matters.
The NHMRC's activities are guided by the priorities identified in the NHMRC
Strategic Plan 2013–2015. Its recent work on wind farms and human health
has taken place under priority area 8 in this plan, which identifies, among
other matters, 'emerging community concerns about the health impacts of new
technologies' as a matter requiring an 'evidence-based approach.'
The NHMRC first addressed the issue of wind farms and human health in
2009 by conducting a rapid review of published scientific literature to
determine whether existing evidence supported concerns regarding infrasound,
noise, electromagnetic energy, shadow flicker and blade glint. This work
culminated in a 2010 public statement which concluded that 'there is currently
no consistent evidence that wind farms cause adverse effects in humans.'
The NHMRC continued to monitor evidence in this area, and hosted a
scientific forum in June 2011, which included 'state and territory health,
planning and environment authorities and other key stakeholders, including
environmental health experts and researchers, acoustic engineers, public
interest groups involved with wind farms in Australia and international experts
from countries with substantial experience in wind turbines.' After
consideration of the results of this forum, the NHMRC commenced a systematic
literature review focused on the possible health impacts of audible noise and
infrasound. The findings of this systematic review have been used to develop a
statement and information paper. As with its earlier rapid review, the
information paper finalised in 2014 concludes that 'there is currently no
consistent evidence that wind farms cause adverse health effects in humans.'
The NHMRC advised the committee that the following steps were taken to
ensure evidence was appropriately identified, assessed and summarised in this
Establishment of the Wind Farms and Human Health Reference Group
under Section 39 of the Act from 1 February 2012 to 31 January 2015
Appointment of two observers to the Reference Group
Disclosure of any interests by Reference Group members and
observers (published on the NHMRC website).
An independent systematic review of evidence up to October 2012
Independent methodological review of the systematic review of
Public consultation on the draft Information paper for period of
45 days from February 2014 (providing 36 submissions).
Review of draft Information Paper by six expert reviewers.
An independent review of additional evidence up to May 2014,
including additional references submitted during public consultation and expert
In examining evidence produced to date on the health effects of wind
farms the NHMRC's expert reference group established there 'were only a small
number of poor quality papers that directly examined the health outcomes of
wind farm emissions.'
As such, the NHMRC announced a targeted call for research into wind farms and
human health on 24 March, which closed on 6 May 2015 after receiving four
applications. The NHMRC outlined the intention of this call for further
There are obvious limitations in existing direct evidence on
wind farms and human health outcomes, and, in funding the TCR, NHMRC intends to
stimulate the research required to build a robust body of evidence to establish
whether there are adverse health effects from exposure to wind turbine
emissions. Up to $2.5 million over five years is available for this work and
outcomes of the TCR are expected to be announced in December this year.
However, NHMRC will only fund high quality research which will provide answers
to some of the difficult issues that have been raised by the review.
Dr Elizabeth Hanna, a member of the NHMRC Wind Farm and Human Health
Reference Group, informed the committee that, in her opinion, sufficient
evidence had already been gathered for the health and scientific communities to
decide that there was no direct link between wind farms and health problems.
She commented as follows on a recent Health Canada study, which came to the
conclusion that there is no association between exposure to wind turbine noise
and any self-reported illnesses:
I would argue that it has reached the satisfaction level,
particularly, when you incorporate the Health Canada study, which actually did
use world's best practice and which did go through a very rigorous methodology
to be able to identify—it was large, it accurately measured noise. Again, it
goes back to the key things of research. If you want to show causation—and this
is the core issue here: is it the wind farm that is actually causing real and
genuine health problems?—then you have to go back to the basic tenets. You have
to show that exposure to a hazard exists. You have to show that there are
actual, real and genuine health harms. We have to show a dose response, such
that if there is no exposure there is no health problem. If there is exposure,
health problems do exist. Then the dose response is a factor—you increase the
exposure and you increase the health issues.
In response to the suggestion that no amount of research will be
sufficient to address the concerns of those opposed to wind farm development,
Professor Chapman commented:
I agree that it is impossible to prove a negative. However
there are many research questions where such lack of proof does not continue to
stimulate serious research into the as yet unproven phenomenon...We have
repeatedly seen anti-wind farm interests reject any findings that do not accord
with their beliefs. The rejection by such interests of the recent large scale
Health Canada study is a prime example of this. The manifest opposition to wind
farms of a majority of this Committee is a sad chapter in the erosion of
evidence-based attempts at policy making in Australia.
Labor Senators reject the criticisms outlined in the majority report of
the NHMRCs process and methodology.
Labor Senators fully support the work of the NHMRC and believe it is the
appropriate body to assess the evidence relating to the health effects of wind
farms and to coordinate further research, should that be deemed worthwhile. The
process conducted to date has been open, transparent and in accord with its
established procedures. Labor Senators note that the NHMRC is currently
assessing proposals submitted in response to its call for further research on this
In light of the NHMRC's engagement with the issue and the nature of its
findings, Labor Senators strongly disagree with proposals put forward in the
committee's interim report to establish an alternative source of advice on
Labor Senators also strongly oppose further recommendations that flow
from this proposal in the committee's report, including that a new National
Environment Protection (Wind Turbine Infrasound and Low Frequency Sound)
Measure be established by the National Environment Protection Council based
on advice from this proposed new scientific body.
These recommendations simply assume, contrary to the available
scientific evidence, that wind turbines do directly cause harm to human health.
Experts advise there is no evidence
that wind farms harm human health
The committee was informed that the NHMRC's position is in keeping with
that of other peak scientific and medical bodies around the world. A
representative of Infigen Energy, Mr Jonathan Upson, noted:
I am not aware of any government, scientific, medical or
regulatory organisation in the world that has come to the conclusion that wind
turbines have a detrimental impact on health.
Indeed, not only has no medical or scientific peak body come to such a conclusion,
it appears that 'wind turbine syndrome' has never been written up in any
indexed medical journal in the world. Professor Simon Chapman made this point,
among a series of others, in his appearance before the committee:
Why have there been no case series or even single case
studies of so-called wind turbine syndrome published in any reputable medical
journal? Why has no medical practitioner come forward with a submission to any
committee in Australia about having diagnosed disease caused by a wind farm?
Where in the world is there even a single example of an accredited acoustics,
medical or environmental association which has given any credence to direct
harmful effects of wind farms? Why has no complainant anywhere in the world
ever succeeded in a common-law suit for negligence against a wind farm operator
if this is a real phenomenon?
Labor Senators note that the majority report made claims about court
proceedings against wind farms. However, it failed to provide evidence that the
court cases it listed resulted in damages due to human health impacts resulting
from wind farm operations.
The conclusions arrived at by the NHMRC have been endorsed by or agree
with the positions of other relevant peak bodies, including the Australian
Medical Association (AMA). The AMA issued a statement on wind farms in 2014
outlining its position:
The available Australian and international evidence does not
support the view that the infrasound or low frequency sound generated by wind
farms, as they are currently regulated in Australia, causes adverse health
effects on populations residing in their vicinity. The infrasound and low
frequency sound generated by modern wind farms in Australia is well below the
level where known health effects occur, and there is no accepted physiological
mechanism where sub-audible infrasound could cause health effects.
Labor Senators respect the decision of the AMA not to participate in the
inquiry. Labor Senators also accept that the AMAs position statement is
evidence-based, clear and unequivocal. We reject the assertion in the majority
report that 'It has been
left to wind farm companies to confirm the AMA's current position'.
The PHAA expressed a similar position to the AMA in its submission to
impacts of wind turbines, including “Wind Turbine Syndrome” and “Vibroacoustic
Disease” have been raised as concerns in the media and some of the literature,
but these collections of symptoms are not recognised medical conditions.
some limitations to the availability of relevant studies, many reviews of the
literature have failed to identify evidence that infrasound (that is low
frequency sound, in the range less than [20 Hz]) has adverse effects on health
at the levels produced by modern wind turbines. Symptoms which people claim are
consequent to wind turbine exposure, may be common in the community and may
sometimes be attributed to psycho-social factors. In general, a relative
minority of those exposed to wind turbines report being affected, and annoyance
is higher in those who are unhappy about the presence of wind turbines.
review of over 60 scientific review articles on wind turbine noise and health
states that "based on the findings and scientific merit of the available
studies, the weight of evidence suggests that when sited properly, wind
turbines are not related to adverse health".
Associate Professor Simon Carlile of the University of Sydney told the
I would like to start out by saying that as a neuroscientist, I
know of no good neuroscientific evidence that wind turbines are harmful to
human health. I also believe that wind turbines will play an indispensable part
in our energy solutions for the future.
The Climate and Health Alliance, which represents 28 health sector
organisations, addressed the issue of wind turbine infrasound, which some
individuals believe leads to human health impacts:
The available Australian and international evidence does not
support the view that the infrasound or low frequency sound generated by wind
farms causes adverse health effects for people living or working in proximity
At distances beyond 500 metres, infrasound and low frequency
sound generated by wind farms in Australia is thought to be below the level
capable of causing health effects to occur, and there is no accepted
physiological mechanism where subaudible infrasound from wind farms could cause
The Australian Association of Acoustical Consultants has published a
position statement which confirms there is no evidence that infrasound from
wind farms is causally related to any human health impacts.
Infrasound (frequencies below 20Hz for the purpose of this
statement) is generated by both natural sources (such as people, wind, waves,
thunder and earthquakes) and mechanical sources (such as fossil fuel power
generation, travelling in a car with windows open, traffic, industry, air
conditioners, aircraft and wind turbines). Investigations
have found that infrasound levels around wind farms are no higher than levels
measured at other locations where people live, work and sleep. Those
investigations conclude that infrasound levels adjacent to wind farms are below
the threshold of perception and below currently accepted limits set for
Labor Senators note with concern that the majority report has implied
that the World Health Organization (WHO) has found the operations of wind
turbines are causally linked to adverse health effects, including
cardiovascular disease and cancer..
This stands in direct contrast to statements made by the WHO in a background
The increased use of renewable energy, especially wind, solar
and photovoltaic energy, will have positive health benefits, some of which have
The ExternE Project considered wind energy to have the lowest
level of impacts (health and environmental), of all the fuel cycles considered.
Labor Senators absolutely respect the testimony of individuals who claim
their health has been impacted by exposure to wind farms and do not doubt that
some individuals are legitimately experiencing symptoms. We do, however,
recognise that there is no evidence of a causal link between the activities of
wind turbines and any physical complaints and are particularly concerned that
genuine medical concerns could be going undiagnosed as individuals mistakenly
attribute legitimate symptoms to the operation of wind turbines.
Many submitters to the inquiry recognised the great contribution of the
Health Canada ‘Wind Turbine Noise and Health Study' to the body of knowledge on
the potential impacts of wind farms on human health. This $2.1 million epidemiological
study, conducted in conjunction with Statistics Canada is the largest of its
kind yet conducted. It incorporated a random sample of over 1,200 houses at varying
distances from wind turbines at six different wind farms, 4,000 hours of
acoustic data, acoustic and medical expertise, self-reported health
questionnaires and objective health measures including hair cortisol, blood
pressure and heart rates.
Health Canada released preliminary research findings in November 2014. Notably,
they failed to find any link between wind turbine noise (WTN) exposure and
The following were not found to be associated with WTN
self-reported sleep (e.g., general disturbance, use of sleep
medication, diagnosed sleep disorders);
self-reported illnesses (e.g., dizziness, tinnitus, prevalence of
frequent migraines and headaches) and chronic health conditions (e.g., heart
disease, high blood pressure and diabetes); and
self-reported perceived stress and quality of life.
While some individuals reported some of the health
conditions above, the prevalence was not found to change in relation to WTN
Health Canada did recognise, however, that 'annoyance toward several
wind turbine features (ie. Noise, shadow flicker, blinking lights, vibrations
and visual impacts)' were 'statistically associated with increasing levels of
Dr Elizabeth Hanna expressed the view that annoyance towards wind farms
is likely to be a very relevant factor in reported health symptoms:
The weight of evidence that I reviewed during my term on the
wind farm panel has led me to believe that there is indeed no evidence that
wind farms cause health problems. Also, I think it is very unlikely that there
are direct health effects. The pathway that I believe is most likely is through
annoyance, and this can generate health symptoms as reported, and these are
very, very real. So at no stage do we discredit the view of people that report
health symptoms, that they are not real in themselves. But the evidence is such
that, when you are of the mindset that you are against a wind farm, or indeed
exposure to anything else, such as RSI—which was 'kangaroo paw' years ago, from
repetitive strain injury—again, it was shown that, if people had a negative
attitude, they were the ones that had a much higher rate of showing symptoms.
This has been shown in several research papers...
Health Canada’s findings concur with an analysis of Public Benefit
Scheme prescription data undertaken by the Head of Medicine at Adelaide
University, Professor Gary Wittert. Four Corners has reported that this
study found no evidence that people living near wind farms were taking more
Labor Senators note that 'Wind turbine syndrome' has been credited with
causing an impossibly wide range of symptoms, which further reduces its
Professor Simon Chapman has compiled a list of symptoms, diseases and
aberrant behaviours, currently including 244 entries, attributed to wind
Labor Senators also note that Professor Chapman has compiled an up to
date list of 25 reviews of the research literature relevant to the wind farms
and health effects, all of which support the conclusion that there is currently
no evidence that wind farms directly cause health problems.
Labor Senators also draw attention to a study undertaken by Professor
Chapman that examined the historical and geographical variations in complaints
regarding noise or health effects from wind farms in Australia. The results of
this study are as follows:
There are large historical and geographical variations in
wind farm complaints. 33/51 (64.7%) of Australian wind farms including 18/34
(52.9%) with turbine size >1 MW have never been subject to noise or health
complaints. These 33 farms have an estimated 21,633 residents within 5 km and
have operated complaint-free for a cumulative 267 years. Western Australia and
Tasmania have seen no complaints. 129 individuals across Australia (1 in 254
residents) appear to have ever complained, with 94 (73%) being residents near 6
wind farms targeted by anti wind farm groups. The large majority 116/129(90%)
of complainants made their first complaint after 2009 when anti wind farm
groups began to add health concerns to their wider opposition. In the preceding
years, health or noise complaints were rare despite large and small-turbine
wind farms having operated for many years.
Labor Senators are disappointed that the majority report has attempted
to discredit Professor Chapman’s eminent professional qualifications, which he
outlined for the committee:
I am Professor of Public Health, University of Sydney. I have
a PhD in medicine and I am a fellow of the Academy of the Social Sciences in
Australia. I have 500 publications in peer-reviewed journals which have been
cited over 9,600 times. My Order of Australia was for distinguished service to
medical research, particularly in the area of public health policy.
I have published five papers and four letters on wind farms
and health in peer-reviewed journals, and I believe I am the most published
Australian researcher in this area. Five of these have been read online over
47,600 times. I have reviewed research on wind farms and health for the
journals Environmental Research, Noise and Health, the International
Journal of Acoustics and Vibration, Energy Policy, the journal Psychosomatic
Medicine, and Cureus.
The findings of Professor Chapman’s research suggest that wind turbines
themselves are not directly harmful to human health. Rather, as he explained,
the highly variable pattern of complaints suggests psychosocial factors play an
important role and that campaigns by opponents of wind farms are strongly
associated with increased complaints:
I have long formed the view that the phenomenon of people
claiming to be adversely affected by exposure to wind turbines is best
understood as a communicated disease that exhibits many signs of the classic
psychosocial and nocebo phenomenon where negative expectations can translate
into symptoms of tension and anxiety. The very obvious differential
spatio-temporal distribution of complaints is the key indicator of this. It
mirrors many past historical health panics about new technologies that have
included the ordinary telephone, trains, television sets, electric blankets,
power lines, computers, mobile phones and towers, and today's wi-fi and smart
The link between expectations and individual’s
perceptions of health impacts
The suggestion that the nocebo mechanism, whereby 'negative expectations
can translate into symptoms of tension and anxiety', would account for such a
pattern of complaints, has found further support in the work undertaken by Ms
Fiona Crichton at the University of Auckland.
It is disappointing that the majority report excludes Ms Crichton’s work
from its considerations. This work presents very compelling evidence that there
is a direct link between people’s exposure to anti-wind messages and their
perceptions of infrasound from wind farms on their health.
Ms Crichton commented on how expectations of negative health effects
from infrasound, based on misinformation, influence the interpretation of
common physiological symptoms:
Exposure to infrasound is a consistent and normal human
experience. Infrasound is produced by air turbulence and ocean waves as well as
by machinery such as air conditioners and by internal physiological processes
such as respiration and heartbeat. Misinformation that exposure to a benign
agent may cause health problems can trigger a nocebo response in the presence
of that agent. A nocebo response occurs when the expectation of adverse health
effects leads to increased symptom reporting. This happens because symptom expectations
guide the detection and interpretation of common physiological symptoms,
including normal somatic arousal caused by hypervigilance and elevated anxiety.
Ms Crichton described peer-reviewed and published research she has
undertaken to 'test the potential for expectations formed by accessing
information disseminated through the media, particularly the internet, to
determine subjective health assessment during exposure to both audible and
subaudible wind farm sound.'
In summary, this research has demonstrated:
...that expectations can influence symptom and mood reports in
both positive and negative directions. The results suggest that how infrasound
is framed can have a determinative impact on subjective health responses during
exposure to wind farm sound, and that positive framing of sound could reduce
reports of symptoms or negative effects. In further experiments, we have used
the same experimental paradigm to investigate whether we can shift negative
expectations once they are formed. This is important information if we are to
address symptom reporting prompted by access to health warnings and negative
beliefs about wind farms. We have found promising indications that changing the
narrative about wind farms will go some way to improving health complaints.
It is important to note that it was consistent across all
experiments that providing people with material on the internet suggesting that
infrasound produced by wind farms is causing symptoms in people living close to
wind farms increased concerns about the health effects of wind farm sounds and
resulted in increased symptoms and mood deterioration during simultaneous
exposure to audible wind farm sounds and infrasound. However, when the
narrative is changed so that more positive expectations or neutral expectations
are formed, the experience is completely reversed. There was also consistent
evidence across the experiments that negative expectations triggered noise
annoyance responses and that positive expectations reduced noise annoyance.
In a similar vein Dr Geoff Leventhall also suggested that misinformation
campaigns by wind farm opponents had played a significant role in exacerbating
reported health impacts:
I believe that many opponents of wind turbines have latched
onto infrasound and have used it as a stick with which to beat wind turbines.
For the past 10 years or more the leading objectors to wind turbines have led a
very successful propaganda campaign against wind turbines, partly based on
supposed dangers of infrasound. They have tried very hard to inculcate negative
attitudes and unhelpful thinking about wind turbines, so setting people up to be adversely affected. We are now in a confused
situation in which many people hold sincere beliefs about infrasound, but these
beliefs are based on false information which have been fed to them by
well-organised objector groups and their allies. This skilful and successful
misinformation campaign, which is largely based on repetition, serves only to
heighten adverse effects whilst holding back research in significant
The Australian Psychological Society noted the stress and anxiety that
stem from misinformation in its submission:
An important cause of community resistance to wind turbines,
therefore, is misinformation that is spread about the impact of wind farms
(e.g., on health, fauna, property values etc) through social groups, via
anecdotal stories, or through anti-wind lobby groups. Concerns might be fuelled
by the popular media, opinion pieces, news articles, websites and word of
’Misinformation’ refers to information that people have
acquired that turns out to be incorrect, irrespective of why and how that
information was acquired in the first place. Once fear and confusion have been
created by misinformation in communities, it can cause ongoing community
division and discord. All of this can lead to increased physiological arousal
and stress symptoms. Many of the health effects which are reported to arise
from wind farms are very common physiological responses to stress and anxiety.
The Climate and Health Alliance also recognised the link between
expectations upon positive or negative health outcomes:
Several studies demonstrated anxiety about the sound source
elevates negative responses, and this underpins a potential source of tension.
The association between expectations and health outcomes dates back to
Hippocrates and is well established in the health psychology literature. The
influence of pre-intervention expectations upon positive or negative outcomes
is consistently demonstrated across a range of health endpoints, including
weight loss, smoking cessation,and post-operative recovery.
The international experience
Labor Senators note important evidence received that entire countries
with significant numbers of installed wind turbines appear to be free of any
community concern regarding their alleged negative health effects.
Professor Chapman stated that concerns about the health impacts of wind
farms appear to be largely restricted to English-speaking countries:
When I travel to Europe, which I do often for my work, I am
often in the presence of colleagues who are working in public health and I
raise this issue with them. Sometimes they say to me, 'Look, what is it that
you are asking?' And I have to go through it again carefully, and they say, 'We
have never heard of anything like this.' Friends of mine who have gone walking
on the pilgrim's walk in northern Spain made an effort to ask local people as
they walked across that, 'Are these wind farms that we are seeing affecting you?'
The people looked at them as if they must be strange. They had never heard of
anything like this.
So it is, as some people have observed, a phenomenon which
perhaps speaks English. Of course, people working in other countries which are
not anglophone do publish a lot in anglophone journals—in English-speaking
journals—so the idea that there would be researchers who have information and
are not putting it out in the English-language academic press is also not very
Ms Kim Forde provided similar testimony about her firsthand experience
of community attitudes to wind farms in Ireland. She stated that 'the
perception of the impact of infrasound, has blown out of all proportion—again,
from people who have fears about the wind farm' and commented that:
I agree that the perception of the exposure to antiwind
messages certainly leads to uncertainty. I am actually in Ireland at the
moment, and I was at an Irish wind farm in the south of Ireland yesterday
speaking with people about exactly this process. They were talking about the
fact that they have almost no protests here against wind farms and they find it
quite amusing that in the places where there are new wind farms being proposed,
places like Australia, there is a protest against it—where there is a protest
group or people with an interest, or some perceived interest, in preventing
them happening. Whereas here, where people have an alternative to
wind—potentially nuclear—these people go, 'We want wind. We can't see a problem
with it. We have them.'
This observation was supported other witnesses. Mr Peter Rae, a former
Liberal Senator for Tasmania with extensive experience in the renewable energy sector,
informed the committee:
In my experience around the world there are a only few
centres where this concern appears to arise and be concentrated.
Overall it is not a matter which arises until the risk of it
is raised by people who do not like having wind turbines placed near to where
I have not heard of any occasion where those who work at operating
wind farms have expressed the health concern.
It follows that, as the complaints arise selectively, then
considerable caution should be adopted in making any findings on the issue and,
in particular, in imposing further restrictions and costs based upon that
Mr Danny Nielsen, Managing Director of Vestas Australian Wind
Technology, also supported this view:
I have worked for Vestas for over 17 years and can nominate
many countries including China, Japan, Taiwan, Korea, Pakistan, India, the USA,
the Philippines, Ireland, Sweden and Greece where the sort of health claims
made by anti-wind energy activists in Australia have not come to my attention
during my time there.
Ms Megan Wheatley of Senvion Australia, in response to a question
regarding the highly uneven global distribution of health complaints regarding
wind farms, made the following statement:
I will answer that by quoting our global CEO, Andreas Nauen.
He was in Australia a few years ago and he was surprised by the level of debate
about wind farms and health. At that time, he spoke about having very specific
discussions in other countries about things like warning lights for high towers
It’s always a very solution orientated discussion... but this
fundamental discussion of wind turbines causing illnesses, I don’t see it
anywhere else in the world.
The committee received a submission and heard evidence from Ms Lilli-Ann
Green, a resident of the United States, who stated she had conducted interviews
with people claiming to be negatively affected by wind turbines in 15 different
countries, both English and non-English speaking.
Ms Green testified that she runs a 'healthcare consultancy', of which
she is the only employee, that has delivered 'educational programs' to 300,000
physicians. However, Ms Green was unwilling to provide the name of her company
to the committee. Ms Green was also unwilling to provide the committee with
transcripts of these interviews or with the names of the interviewees. Ms Green
further informed the committee that the subjects of her interviews were a
self-selected group with pre-existing grievances about wind farms based either
on perceived health effects or other matters. Finally, Ms Green stated that she
has no qualifications in health care or medicine.
Labor Senators caution that, based on the scant detail supplied, Ms
Green's series of interviews appears to have no scientific value if taken as a
study of community reactions to wind farms in different countries.
Labor Senators are convinced that there are notable differences in the
level and nature of concerns about wind farms in different countries. This
uneven distribution of concerns suggests that factors other than direct causal
links between wind turbines and health impacts must be considered.
Thousands of wind farm workers
suffer no ill-effects
A further difficulty confronting claims that wind turbines are directly
harmful to human health, whether via infrasound emissions or by some other
mechanism, is presented by the fact that the workforces of wind turbine
manufacturers and operators report no such ill effects, despite working in very
close proximity to wind farms on a daily basis. In response to a question
regarding the health effects of infrasound, Mr Ken McAlpine of Vestas
Australian Wind Technology, stated:
...we have employees who work at close range to wind turbines
every day of the year in all sorts of conditions. You would expect from that
that, if there were something harmful coming from the machine or its operation,
our people would be first in line to cop it.
We have 5½ thousand people who work out in the field
operating wind turbines. They work inside them. They go up. They have sites
that are within hundreds of metres of the turbines themselves. It is not just
manufacturing that Vestas does; it is an operator of wind turbines too.
Senvion Australia, a company that employs over 3,400 people and has
installed over 6,000 wind turbines, also submitted that its workforce appeared
to be completely unaffected by working in close proximity to wind turbines and
wind farms on a daily basis.
Their submission states:
As a company with employees working on operating wind
turbines and living near wind farms, we have not seen any ill health effects
resulting from wind energy generation.
Their submission also quoted one of their engineers, James Miele:
I have spent a huge amount of time living and working in the
vicinity of wind turbines. I can state without any doubt that neither I or
anybody I know has ever experienced any ill effects from wind turbines.
The committee received considerable volumes of evidence relating to
infrasound—that is, sound below a frequency of 20 Hz—and devoted time at its
public hearings to discussing the possibility that infrasound emitted by wind
farms might directly affect human health.
While the majority report seeks to suggest the World Health Organization
supports the proposition that wind turbines have human health impacts, the WHO
explicitly outlines the safe level of infrasound exposure:
Sound characterised by frequencies between 1 and 20 Hz is
called infrasound and is not considered damaging at levels below 120 dB..
Labor Senators note that wind farms constructed under Australian
planning regimes would never exceed the levels outlined by the WHO.
Mr Christopher Turnbull from the Association of Australian Acoustical
Consultants explained that infrasound from wind farms is very similar to
infrasound from other sources:
Certainly the level of infrasound from wind turbines is very
similar to the level of infrasound from other sources. I have personally
measured the noise from waves at beaches and at cliffs in the city and in other
areas; other members of this panel have, for example, measured the infrasound
produced by the change in pressure as people walk; and the levels of infrasound
from a wind farm are very similar to those levels that we have just described.
In relation to whether the research supports the idea that wind farms
may have human health impacts, Mr Turnbull said:
I am not aware of any that has found a link between wind
turbines and health. I have certainly read some articles which indicate that
there is a hypothesis that there might be, but I have certainly not seen any
direct link in any paper that I am aware of.
Dr Renzo Tonin of the AAAC also confirmed that there are no studies
confirming that infrasound from wind farms has human health impacts:
All of the research articles that have been published
claiming links between wind farm noise and health basically set a hypothesis
for a connection between infrasound and the ability of the human body to
respond to that infrasound. They do not prove a connection in any way between
adverse health and infrasound..
Dr Tonin went on to explain the research he had personally completed in
Therefore, what I did in my research last year, presented at
the Wind Turbine Noise conference just recently, was to take the highest level
of measured infrasound, which to date has been at the Shirley Wind Farm and
which I believe the senators would be aware of, and consented to 72
participants ranging in age from about 18 to the late 60s I think it was. What
we found was that in presenting that level, which is at a level of 90 decibels
at 0.8 Hz and the highest measured anywhere in the world to date, there was no
correlation between that level of infrasound and a person's reported
symptoms—and there were about 20 different symptoms...
The assertion that there is something unique or different about
infrasound from wind turbines that may be leading to human health impacts was
disputed by acoustician Dr Norm Broner:
Infrasound level in various situations has now been fully
documented. Infrasound level near to wind turbines is really not that different
from many other anthropomorphic and natural noise sources—for example, walking
on the beach or travelling in a car, train or plane, you are exposed to levels
of infrasound either higher or similar to those from wind turbines. I would
hazard a guess that where the committee is currently sitting today you are
exposed to levels of infrasound similar to that generated by wind turbines. But
I do not think any of you would be claiming that you are not feeling well
because of it.
Dr Broner noted work in Japan by Tachibana which found no problems with
infrasound from wind turbines..
Testimony from Mr Peter Dolan of the South Australian EPA supported the
position that infrasound from wind turbines is imperceptible by humans:
With infrasound, the lower the frequency, the harder it is to
perceive, and it is generally accepted that you cannot perceive infrasound
until 85 dBG, which is the range we tend to use. The levels we are finding near
wind farms are much, much lower than that; they are in the order of 30 dBG.
Mr Dolan also rejected the suggestion that individuals are adversely
affected by infrasound from wind turbines:
I am not aware of evidence that thousands of people are
adversely exposed. I am aware that we probably have three-quarters of the
million people in Adelaide exposed to excessive traffic related infrasound. We
are really talking about the difference between the nature of infrasound from a
wind farm and from other sources, because, clearly, many millions of
Australians are affected by infrasound from road traffic.
A study conducted by the South Australian Environment Protection Authority
came to the following conclusions regarding infrasound from wind turbines:
From an overall perspective, measured G-weighted infrasound
levels at rural locations both near to and away from wind farms were no higher
than infrasound levels measured at the urban locations. The most significant
difference between the urban and rural locations was that human activity and
traffic appeared to be the primary source of infrasound in urban locations,
while localised wind conditions appeared to be the primary source of infrasound
in rural locations. Of particular note, the results at one of the houses near a
wind farm (Location 8) are the lowest infrasound levels measured at any of the
11 locations included in this study.
This study concludes that the level of infrasound at houses
near the wind turbines assessed is no greater than that experienced in other
urban and rural environments, and is also significantly below the human
Former President of the United Kingdom Institute of Acoustics, Dr Geoff
Leventhall, noted that there is significant misunderstanding regarding
infrasound from wind turbines:
There are many misconceptions about infrasound. It has even
become associated with surreal and paranormal events or described as a subtle
weapon and cause of illness. Much of this misunderstanding arises from not
appreciating that the word 'infrasound' used on its own has only a limited
meaning related to a frequency range. Full meaning comes from the inclusion of
actual frequencies and levels. One should not make claims about infrasound
without also giving the relevant frequencies and levels.
Dr Leventhall also rejected the theory that infrasound from wind farms
could be causing human health impacts:
In a paper I published nearly 10 years ago about infrasound
from wind turbines I said that wind turbines produce infrasound but the levels
are very low and of no consequence. Wind turbines produce low-frequency noise,
especially when there is turbulence in the inflow air, and the low-frequency
noise can sometimes be audible. But we hear low-frequency noise all the time.
It is not something to be afraid of.
Labor Senators support the NHMRC's effort to encourage further rigorous
research on wind turbines and human health; however, it is important to note
that the inherent characteristics of infrasound make it a very poor candidate
as an explanation for the range of symptoms attributed to the operation of wind
farms. First, infrasound emissions from wind turbines are not generally of
sufficient sound pressure level to make them perceivable.
Second, infrasound is present in all environments, both rural and urban, and
often at higher levels than those recorded near wind farms.
Arguments suggesting infrasound emissions from wind farms are dangerous
to human health must therefore overcome the obvious difficulties that such
emissions are imperceptible and that they are also found, often at higher
levels, in non-wind-farm exposed environments without any reported health effects.
No convincing evidence to counter these objections was provided to the
The Cape Bridgewater study
The recent study of Pacific Hydro's Cape Bridgewater wind farm conducted
by Mr Steven Cooper of the Acoustic Group Pty Ltd was cited by some as evidence
of a direct link between infrasound emissions from wind farms and reported
symptoms of nearby residents.
Many of the majority committee members raised particular concern about the
implications of this study.
However, Labor Senators note that Mr Cooper and Pacific Hydro issued a
joint statement on 16 February 2015 emphasising, among other things, the
The Acoustic Group and Pacific Hydro agree that the study was not
a scientific study.
The Acoustic Group and Pacific Hydro agree that the report does
not recommend or justify a change in regulations.
The Acoustic Group and Pacific Hydro agree this was not a health
study and did not seek or request any particulars as to health impacts.
Labor Senators assert that the claim in the majority report that 'Mr
Steven Cooper found a correlation between infrasound emitting from turbines at
Cape Bridgewater and 'sensations' felt, and diarised, by six residents of three
nearby homes' is incorrect and has been thoroughly and effectively discredited
by multiple witnesses to the inquiry.
Both Pacific Hydro and Mr Cooper have emphasised that the study was
undertaken within a very limited brief. The intention of the study was only to
'see whether any links could be established between certain wind conditions or
sound levels at Cape Bridgewater and the disturbances being reported by these
six local residents' noting that the windfarm is compliant with relevant noise
Beyond these limitations, the study was also severely criticised by
expert acousticians on the basis of apparent flaws in its methodology. For
example, the Association of Australian Acoustical Consultants (AAAC) reviewed
Mr Cooper's Cape Bridgewater study and came to the following conclusions:
The overall conclusion drawn from the review is that the
Study provides no new credible scientific evidence, and further, no scientific
evidence to support the media reporting positively of the Study.
The Study measures infrasound at the blade pass frequency and
multiples of the blade pass frequency. The level of infrasound is similar to
the levels measured previously by others and is well below the threshold of
The Study suggests that there is a "pattern" of
high severity disturbance associated with four turbine operating modes. When
all data are considered, there are limitations, contradictory and limited data
and the results do not support the description of a "pattern".
The Study includes a hypothesis that "sensations"
felt by the participants might be related to the measured level of infrasound.
The hypothesis is based on a very limited subset of the data, with any data
excluded from the analysis if it did not fit the theory. When all data are
considered, the evidence does not support the hypothesis.
The AAAC elaborated on this critique in its appearance before the
The problem is that those occasions when people felt these
sensations when the turbines were off were simply ignored in any analysis that
was conducted. If you are to conduct analysis, it needs to be done on a
statistical basis by a statistician who understands all of the compounding
factors and has a scientific approach rather than simply ignoring things and
choosing the data that suits the theory they might have.
In response to Mr Cooper's claim that his study had been 'hailed around
the world as finding new information and material previously not put together
or understood with regard to windfarms', and that his methodology should
therefore be repeated in expanded studies, the AAAC informed the committee
What Mr Cooper has done is nothing new. He has measured what
is called the wind turbine signature, which, as Mr Turnbull has said, has been
around for decades. We all know about that. In fact, if you look at the Shirley
wind farm it presents the same information. So there is nothing new about that.
Mr Cooper suggests that what he has done should form the basis of monitoring at
all wind turbines. I do not agree with that. What we need to get to the heart
of are the claims that link infrasound and health. You do not do that by
following Cooper's methodology. You do that by exploring the next step of the
Creighton/Tonin and hopefully NHMRC methodology, which is to expose people to
exactly what some people complain of and to scientifically and medically
measure the health responses and the symptoms to that exposure. That is the way
forward. I would hopefully suggest that senators give support to the NHMRC
funding to come on-stream later this year to do just that.
Dr Leventhall, who has significant expertise in the area of infrasound
also expressed the view that the Cooper report did not establish any new
connection between infrasound and health effects:
This report has received many plaudits in the media, ranging
from “ground-breaking” to “pointing the way for future medical research”.
Following a detailed study of the report, I do not agree that these plaudits
are deserved. The report is useful in its detail, but it reveals little new and
has ignored what should be its most obvious conclusions. It is clear that Mr
Cooper came to the work with the firm conviction that inaudible infrasound was
a problem and cared only to develop that theme. However, what the report
actually shows is that those affected are responding to audible noise, and exhibiting
well known stress responses to an unwanted noise, even though this noise is
normally at a very low level. The report indicates that infrasound is not an
Dr Elizabeth Hanna also emphasised that the Cape Bridgewater study did
not meet any of the methodological requirements needed to establish an
association between exposure to wind turbines and health effects, whereas the
Health Canada study did meet these requirements and found no such association:
You also have to make sure that any health reported issue is
not caused by other reasons, or by the fact that a lot of people cannot sleep,
a lot have tinnitus, a lot have high blood pressure and so on and so forth. You
have to be able to determine the fact that there is a real and genuine increase
in the standard health problems—the 150 or so that have been attributed. You
have to be able to show that there is a marked and significant elevation in
those health problems for those people who are living in proximity, close
enough, and are actually exposed. You also have to show the time scale—the fact
that they were healthy, exposure happened, and then they got sick. It is a
complex, quite detailed and very expensive study that would need to be able to
show that. Health Canada did a particularly good job at that, as compared to
the study that has so often been reported in this committee—Cooper's
study—which was not a scientific study, as he would argue.
Labor Senators note that Mr Cooper testified in proceedings against the
Stony Gap Wind Farm in the South Australian Environment, Resources and
Development Court. Mr Cooper’s evidence was dismissed, with the judgement stating
the following in relation to Mr Cooper’s work:
At present, on the basis of his evidence before us, it seems that his approach to the task includes privileging the
subjective experiences of those residents who have experienced problems, and
their perceptions as to the cause of these experiences, over other
contradictory data. The investigations by the EPA and Mr Turnbull in relation
to the same or similar material have not yielded any basis for refusing to
grant development plan consent to the proposed development on the basis of
noise generally, infrasound or low frequency noise.
Labor Senators believe the evidence received by the committee supports
the contention that Mr Cooper has employed a similar approach in the Cape
Bridgewater study that he was criticised for by the South Australian court.
Labor Senators conclude that the Cape Bridgewater study conducted by Mr
Cooper provides no scientific evidence of a connection between infrasound
emitted by wind farms and health effects and that this study does not provide a
foundation for changing the planning and monitoring regime governing wind
Response to specific health impact
claims in the majority report
The majority report makes reference to a number of sources to support
the proposition that wind farms are directly linked to human health impacts.
Labor Senators are not persuaded that any of the sources provided offer any
credible evidence of health impacts from wind farms.
The majority report devotes significant space to the testimony of Ms
Sarah Laurie to support its contention that wind farms are the direct cause of
human health impacts. Ms Laurie was once a registered doctor but, after a
complaint was filed with the Australian Health Practitioner Regulation Agency
in 2013 that her activities constituted practice as a physician, Ms Laurie
voluntarily agreed not to use the title Doctor.
Labor Senators note that Ms Laurie’s evidence has been rejected in a
number of court proceedings against specific wind energy developments.
Mr Laurie gave evidence against the Stony Gap Wind Farm in 2014, but it
was rejected by the judge, who made the following findings:
Dr Laurie's evidence does not contain
evidence (whether from her own research, or that of others) of a causal link
between contemporary operating wind turbines and the kind of health problems
reported by the deponents, which is consistent with any accepted scientific or
legal method of proof.
Dr Laurie wishes to have investigated
the theory that some people are "so exquisitely sensitised to certain
frequencies that their perception of very, very low frequency is right off the
shape of the bell curve", such that they can, for example, from Australia,
perceive an earthquake in Chile.
Dr Laurie rejects all of the studies,
including the EPA studies, which are not consistent with her theories. She
admits that evidence showing a causal connection between contemporary wind
farms and health effects does not exist, and she seeks to have more research
done in the hope that such evidence will be generated in the future.
There is no basis for the refusal of
development plan consent to the proposed development on the grounds of health
In 2013 Ms Laurie participated in a case relating to the Dufferin Wind
Power Project, which went before the Environmental Review Tribunal in Ontario,
Canada. In this case, the tribunal rejected claims of human and animal health
impacts. It also refused permission for Ms Laurie to give opinion evidence (the
equivalent of expert evidence in Australian courts). It went into extensive
detail on its reasons for this decision over many pages. A small excerpt
However, the Tribunal has already
found that Ms. Laurie cannot be qualified to give opinion evidence based on
formal medical or scientific research, or research design and methodology. The
Tribunal has also found that she cannot be qualified to give opinion evidence requiring
diagnostic opinions, or the application of diagnostic interpretation to
formulate conclusions on the potential health impacts of exposure to operating
industrial wind turbines. This raises the question whether she can be qualified
to give her proposed opinion evidence on the basis of the experience she has
obtained through self-study of the published research and other literature. The
Tribunal accepts that the time Ms. Laurie has devoted to this aspect of her
work experience is not insignificant. However, Ms. Laurie’s evidence does not
indicate that she has conducted a comprehensive review of all literature, nor
that she has the expertise to assess the sufficiency of the research
methodology in individual research studies. Consequently, the Tribunal finds
that her self-study of the published literature, as described in her witness
statement, even if considered in conjunction with her survey of self-identified
participants, is not sufficient to meet the basic threshold of reliability
necessary to assist the Tribunal in making a sound decision.
In summary, the Tribunal has found that the Appellant, Mr.
Sanford has not established a basis on which Ms. Laurie can be qualified to
give her proposed opinion evidence in this proceeding.
In 2013, Ms Laurie was given permission to testify in a hearing for the Bull
Creek Wind Project in Alberta, Canada. However, in its decision the
Alberta Utilities Commission made these comments about Ms Laurie:
Dr. Laurie’s written
evidence also included her interpretation and discussion of numerous published
and unpublished epidemiological and acoustical reports and studies. In the
Commission’s view, Dr. Laurie lacks the necessary skills, experience and
training to comment on the interpretation of epidemiologic studies or the
interpretation of acoustical studies and reports. The Commission gave little
weight to this aspect of Dr. Laurie’s evidence.
Labor Senators are persuaded that testimony from Ms Laurie regarding the
health impacts of wind farms should be treated with caution.
The majority report also calls upon evidence from Ms Laurie about a
number of studies ‘that has identified adverse health effects on humans of low
frequency sound’, including work completed by Dr David Iser, Professor Alex
Salt and the Inagaki study in Japan.
The majority report refers to Dr David Iser as ‘the first General
Practitioner in Australia to report adverse health effects from wind turbines’..
Dr Iser, testified to the committee that, as a local general
practitioner, he was made aware that there may be adverse health impacts of
wind farms. Dr Iser told the committee that, as a result, he undertook a
literature review with the outcome that ‘there were no significant adverse
health effects of a physical nature that I could find in the literature’.
With this in mind, Dr Iser distributed 25 questionnaires to residents
living near the Toora Wind Farm to determine if there were any health problems.
Among the respondents, 12 reported no health problems, 5 reported mild
problems, and 3 reported ‘major health problems including sleep disturbance,
stress and dizziness’.
In response to his testimony, Dr Iser was asked a number of questions on
notice about his survey, including whether he attempted to determine a direct
causal link between wind farms and respondents’ concerns, whether he asked any
questions in an attempt to rule out other potential causes of health impacts
and whether he received any substantiating medical data from the respondents.
Dr Iser did not respond directly to the questions put to him on notice. Instead,
he stated 'my reply is based on the fact that the survey was very much an
Due to the small sample size and the lack of any attempt to determine
the wider medical context of individual respondents, Labor Senators do not
believe that Dr Iser’s questionnaire provides evidence of a causal link between
wind turbines and human health.
Labor Senators are also disappointed that the majority members of the
committee chose to highlight this unscientific study while failing to recognise
the extensive and scientifically-grounded processes of the NHMRC's work on wind
Another researcher mentioned in the majority report is Professor Alec
Salt, who is described as 'the leading expert in inner ear fluid physiology,
detailing the effects of low frequency sound on the ear and how wind turbines
can be hazardous to human health. '
This assertion does not concur with the findings of the majority of
medical and acoustical experts and bodies outlined earlier in this chapter.
Professor Salt’s claim was specifically criticised by Bolin et al in a
peer-reviewed article on infrasound and low frequency noise from wind turbines:
Salt and Hullar (2010) hypothesized from previous research
that the outer hair cells are particularly sensitive to infrasound even at
levels below the threshold of perception. In their article, the last paragraph
mentions that wind turbines generate high levels of infrasound, with reference
to three articles, two of which are not relevant to exposure in residential
environments (Jung and Cheung 2008, and Sugimoto et al 2008). No
references were made to published compilations of knowledge that indicates that
the infrasound to which humans are exposed to by wind turbines is moderate and
not higher than what many people are exposed to daily, in the subway and buses
or at the workplace (e.g. Leventhall 2007, Jakobsen 2005). It is therefore
hard to see that Salt and Hullars' results are relevant for risk assessment of
wind turbine noise in particular.
In the same article, Bolin et al concluded that:
The dominant source of wind turbine low frequency noise, LFN
(20–200 Hz), is incoming turbulence interaction with the blade. Infrasound
(1–20 Hz) from wind turbines is not audible at close range and even less
so at distances where residents are living. There is no evidence that
infrasound at these levels contributes to perceived annoyance or other health
effects. LFN from modern wind turbines are audible at typical levels in
residential settings, but the levels do not exceed levels from other common
noise sources, such as road traffic noise. Although new and large wind turbines
may generate more LFN than old and small turbines, the expected increase in LFN
In response to a question about the Inagaki study, which the majority
report claims 'found
physiological effects from aerodynamic sound from wind turbines',
the AAAC wrote:
With regards to infrasound, the Inagaki study played a
synthesised level of infrasound to subjects at a level of 92 dB(G) and a
frequency of 20 Hz. The level of 92 dB(G) is significantly higher than that
produced by modern wind turbines even very close by, and furthermore is at or
near the mean hearing threshold for infrasound. It is therefore not surprising
that some subjects may have perceived the sound at these artificially high
levels. Additionally, 20 Hz is not a common infrasonic frequency associated
with wind turbines, with blade pass frequencies occurring at frequencies lower
than 10 Hz.
The majority report also calls upon the work of Nina Pierpont, who is
credited with coining the term ‘Wind Term Syndrome’ in her self-published book
of the same name. Labor Senators note that this work has been heavily
criticised as having no scientific value.
Specifically, Dr Pierpont’s work has been criticised for having a tiny,
self-selected sample group, acceptance on hearsay on additional people as
direct evidence, no control group and no medical examinations or medical data
Professor Chapman has outlined a number of flaws in Dr Pierpont’s work:
Her reputation as an authority on “wind
turbine syndrome” is a 2009 self-published book containing descriptions of the
health problems of just 10 families (38 people, 21 adults) in five different
countries who once lived near wind turbines and who are convinced the turbines
made them ill. With approximately 100,000 turbines worldwide and uncounted
1,000s living around them, her sample borders on homeopathic strength
Labor Senators also note that the symptoms reported by Dr Pierpont as
being attributable to ‘Wind Turbine Syndrome’ are actually very common. Ms
Fiona Crichton, who has done work on the prevalence of symptoms in the general
population said on this matter:
Further, the experience of symptoms is very common. In fact, a
recent population survey we conducted in New Zealand found that almost 90 per
cent of respondents experienced at least one symptom over the past week, the
median number of symptoms experienced was five and 23 per cent of the
population reported 10 or more symptoms. Therefore, it is very simple for
individuals to misattribute their common experience of symptoms to an innocuous
environmental agent if they have health concerns about exposure to that agent.
The majority report also notes the Shirley Wind Project in the United
States has found that the Shirley Wind Farm was 'a human health hazard'.
In relation to this Project, the AAAC wrote:
The Shirley Wind Farm report did not prove a link between
infrasound from wind farms and health impacts.
“The four investigating firms are of the opinion that enough
evidence and hypotheses have been given herein to classify LFN and infrasound
as a serious issue, possibly affecting the future of the industry. It should be
addressed beyond the present practice of showing that wind turbine levels are
magnitudes below the threshold of hearing at low frequencies.”
The conclusion is that infrasound is a “serious issue” which
could “possibly” affect the industry but that there should be further
That is not the same as saying there is a proven link.
Labor Senators also note a news report from 3 March 2015 that the Brown
County Health Board met and were unable to agree on the next step to be taken
regarding the Shirley Wind Farm.
Reference was also made in the majority report to Professor McMurtry’s 'peer
reviewed papers on the criteria for diagnosis of illness from wind turbines.'
Regarding Dr McMurtry’s work, Labor Senators note these criteria were published
in the Bulletin of Science, Technology and Society.
The Bulletin of Science, Technology and Society is notable in
that it has published the great bulk of the literature purporting to support a
link between wind turbines and human health. For example, in one listing of ‘21
Peer Reviewed Articles on the Adverse Health Effects of Wind Turbine Noise’
posted on a prominent wind opposition website, every single article comes from
Professor Chapman provided evidence to the committee that this publication
was de-indexed 20 years ago:
But after 1995 it was dropped from the list of journals being
indexed, generally a sign that indexing services regard a journal as having
fallen below an acceptable scientific standard..
In the same response to questions on notice, Professor Chapman also
pointed out that Dr McMurty’s claim that the publication is indexed in Index
Medicus is incorrect, as Index Medicus itself ceased publication in 2004.
Dr McMurty’s case definition was also dismissed as evidence in the Ostrander
Point tribunal, Alliance to Protect Prince Edward County v. Director, Ministry
of the Environment in 2013. On this case study, the decision read:
With respect to the proposed Case Definition of AHE/IWTs, the
Tribunal finds that it is a work in progress. It is preliminary attempt to
explain symptoms that appear to be suffered by people with whom Dr. McMurtry is
familiar, who live in the environs of wind turbines. Dr. McMurtry’s case
definition has admittedly not been validated; thus there is currently no
grouping of symptoms recognized by the medical profession as caused by wind
It should also be noted that Dr McMurtry is the founder of the wind
opponent group ‘Society for Wind Vigilance’ and owns a property 1½ kilometres
from a proposed wind farm, which Dr McMurtry testified is currently before the
Speaking more broadly of witnesses who appeared before the committee,
Labor Senators note that, of those who called on their professional expertise
to argue that wind farms cause human health problems, many have a personal
history of opposing wind farm developments near their own residences. Labor
Senators note that this background raises questions regarding the impartiality
of their evidence.
The majority report also refers to ‘ground breaking work’ from Dr Kelley
at NASA in the 1980s in support of its claim that infrasound is leading to
human health impacts.
In response to a question on notice regarding Dr Kelley’s work, the AAAC
The NASA research referred to is the 1985 investigation of a
downwind turbine known as the MOD-14.Downwind turbines are no longer used as
they are known to generate significant levels of infrasound because of the
impact of the tower wake on the turbine blades. Modern wind turbines are constructed
with the blades forward of the tower and generate much less infrasound. There
were no conclusions regarding noise and health other than that the noise caused
Dr Leventhall explained that Kelley had gone on to do work on the MOD2
wind turbine design, which followed the MOD1:
The type of downwind wind turbine which Kelley investigated
(MOD1) no longer exists. But following the MOD1 work a new design, the MOD2,
was developed. This is superficially similar to modern turbines. Kelley’s conclusions
on the MOD2 were “We determined from our analysis of both the high- and
low-frequency-range acoustic data that annoyance to the community from the 1983
configuration of the MOD-2 turbine can be considered very unlikely at
distances greater than 1 km (0.6 mile) from the rotor plane.”
Over the 30+ years since the MOD2 was designed there have
been further developments in reducing wind turbine noise and the 1km estimate
will have shrunk.
I do not believe that Kelley showed “sleep disturbance and annoyance
symptoms which were scientifically established to be directly caused by
infrasound and low frequency noise at levels well below the thresholds of human
hearing” as stated in your question.
Comparative health impacts of
different forms of energy generation
Finally Labor Senators note that the lack of scientific evidence linking
wind farms to human health effects stands in stark contrast with the
well-established evidence of health harms arising from other forms of energy
generation. As with other terms of reference in this inquiry, Labor Senators
believe that a proper evaluation of wind power can only be reached if it is
examined in comparison to other generation types.
The PHAA supported this position:
...we submit that any potential health impacts of wind turbines
need to be assessed within the broader context of the health impacts on
individuals and society from all energy choices and that the broad health and
energy needs of the 21st century economy and society, faced with the prospect
of runaway global warming if we do not rapidly reduce greenhouse gas emissions,
is as much as—we are in strife if we do not reduce our emissions as much as
technologically feasible, starting as soon as possible.
In this context we argue that wind turbines can make an
important contribution to human health and wellbeing, which offsets the noise
disturbance effects on a minority of people. The balance of evidence currently
suggests that although wind turbines are not completely free of all harm to
neighbouring populations, in comparison with non-renewable energy sources,
particularly fossils fuels and nuclear energy, they are likely to be
considerably less harmful in both the short and long term, at a population
level, than these alternatives.
The Climate and Health Alliance's Health and Energy Choices:
Background Briefing Paper provides a summary of the evidence concerning the
health impacts of different forms of energy generation. It documents the
following impacts of fossil fuel based energy production in Australia:
Communities across Australia are being affected by coal
mining, transportation and combustion, and unconventional gas exploration and
production. Communities living near proposed coal mines, coal mine expansions,
coal seam and shale gas extraction potentially face displacement, water
insecurity, air and noise pollution, risks to water quality, loss of amenity
and social capital, and serious physiological and psychological health risks.
Those being exposed to coal transport face unacceptable levels of noise and air
pollution that regularly breach air quality standards. Those living in
proximity to coal fired power stations face risks of respiratory,
cardiovascular, neurological disease and developmental effects. Air pollution
from transport kills more people each year than the road toll.
A World Health Organization background document for the Fourth
Ministerial Conference on Environment and Health outlined the comparative
health impacts of different energy sources.
Figure 1—Years of life lost from acute and chronic air
pollution effects per TWh (Source CIEWAT 1998)
Figure 2—Occupational accidents (deaths per TWh) (CIEWAT
Labor Senators emphasise that, in light of the evidence put before the
committee, the impacts of wind power on the health of the Australian community
must be considered very minor in comparison to the impacts attributable to
established fossil fuel generation methods. Any reasonable examination of the
public health impacts of wind power must take into account this context.
the implementation of planning processes in relation to wind farms,
including the level of information available to prospective wind farm hosts
Labor Senators note that the Intergovernmental Panel on Climate Change (IPCC)
has cited 'cumbersome and slow planning, siting and permitting procedures' as a
significant challenge facing wind energy generation and noted that many
countries with sizable wind resources have not deployed significant amounts of wind
energy partly as a result of this factor.
Labor Senators believe that recommendations contained in the committee's
interim report would significantly increase the regulatory and cost burdens
faced by wind farm proponents and operators in Australia by unnecessarily
duplicating planning regulations concerning sound emissions. These duplication
proposals extend to the establishment of both a distinct scientific advisory
body to deliver exactly the service currently provided by the NHMRC and a
'national wind farm ombudsman' to provide a 'referral service' to the currently
existing planning complaint regimes and ombudsmen at state and territory level.
These proposals will needlessly increase the complexity of the current planning
regime and impose an unjustifiable penalty on the wind industry via a proposed
Labor Senators emphasise that planning processes governing wind farms in
Australia are primarily the responsibility of state and territory governments
and should remain so. These processes fall within the broader category of land
use planning and the Commonwealth Government has not generally intervened in
this area of governance.
As detailed below, Labor Senators believe that the planning processes
operating in state and territory jurisdictions are effective and that no
evidence has been presented during this inquiry that would justify Commonwealth
intervention. Furthermore, no coherent arguments have been presented which
would justify Commonwealth intervention in the specific case of wind farm developments
but not in the case of other energy generation developments with
well-established health and environment impacts, such as coal seam gas
extraction or coal mining and combustion.
Dr James Prest, Australian Centre for Environmental Law, emphasised that,
whereas the states and territories and the Federal Parliament have continued to
enact environment protection legislation, land use planning law has been
undertaken by the states and territories. The only exceptions to this division
of responsibilities have occurred where the Federal Parliament has made land
use planning laws for parts of Canberra and the ACT and for external
It has been the generally accepted position that state and territory
governments are responsible for land use planning and the planning law statutes
in the eight mainland state and territory jurisdictions have been established
on this basis.
There are also statutes governing noise limits in each of these jurisdictions.
Dr Prest also emphasised that any attempt by the Commonwealth to
intervene in this area would be contrary to the terms of the 1992 Intergovernmental
Agreement on the Environment, which explicitly states that, with regard to
resource assessment, land use decisions and approval processes 'The development
and administration of the policy and legislative framework will remain the
responsibility of the States and Local Government.'
As was further argued by Dr Prest, such intervention would also be
contrary to the principles of the National Review of Environmental Regulation,
agreed to by Environment Ministers in 2014, in so far as such new Federal
legislative provisions are 'inconsistent with or in contradiction to State laws
on wind farms or indeed in conflict with the intent of existing Federal laws'.
With regard to the current operation of the state and territory based
planning regimes, the committee received evidence that wind farms are subject
to some of the strictest regulations in the world. For example, the Clean
Energy Council stated:
Wind farms in Australia currently face among the toughest
guidelines in the world in relation to their siting, operation and permissible
In its 2010 Wind Farms Technical Paper: Environmental Noise,
consulting firm Sonus reported on the regulation of noise from wind farms in
Australian jurisdictions presently assess the noise from wind
farms under a range of Standards and Guidelines applicable to each individual
State or Territory.
The Standards and Guidelines used in Australia and New
Zealand are stringent in comparison to other International approaches. They are
also the most contemporary in the World, with recent updates and releases of
the main assessment approaches occurring in both late 2009 and early 2010.
This report also contains a summary of noise standards that are applied
to wind farms in international jurisdictions and lists the common elements that
applied in Australian jurisdictions at the time of publication:
Objective standards that provide a base noise limit and a
background noise related limit, with the exception of the EPHC draft Guidelines
and the Australian Standard;
A background noise and wind speed measurement procedure to
determine the applicable background noise related limits at each dwelling;
A noise level prediction methodology to enable a comparison of
the predicted noise level from the wind farm against the noise limits at each
The required adjustments to the predicted noise levels to account
for any special audible characteristics of the wind farm noise;
A compliance checking procedure to confirm the operational wind
farm achieves the predicted noise levels at each dwelling.
Vestas also noted that, with reference to the 2010 Sonus report, 'it is
fair to say many Australian wind farm planning regulations have become more
restrictive since then. In late 2011 the NSW government released what the
Planning Minister at that time called "some of the toughest windfarm
guidelines in the country, possibly the world".'
With regard to the regulation of sound levels from wind farms, including
infrasound, state and territory planning and environment protection bodies
informed the committee that they rely on the advice of the respected scientific
and health advisory bodies such as the NHMRC and World Health Organisation.
Labor Senators note that state and territory governments and planning
bodies, as well as wind farm developers, are well aware of the need to ensure
effective consultation occurs with the community in the vicinity of wind farm
proposals. For example, the South Australian Government informed the committee:
Wind farm developers recognise the need for good community
consultation and spend considerable hours with their prospective communities
explaining their development and fielding questions. An example of good practice
in South Australia is the Trust Power Palmer Wind Farm development. The company
sends regular newsletters to stakeholders, has undertaken community meetings
and employed a community liaison person who lives in the local area to assist
with information dissemination. They have developed the concept of
neighbourhood agreements whereby non-host residents who live nearby a wind
farm, but who are not hosts, can benefit financially from the development.
The ACT Government emphasised that it views engagement with the local
community as pivotal to 'delivering best wind farm outcomes.' To ensure this
occurs for wind farms projects it supports, the ACT Government has:
...committed to the implementation of good community
engagement practices by renewable energy industries. A major part of this
commitment has been a significant community engagement evaluation criterion
that was incorporated into the assessment of proposals submitted to the ACT's
2014/2015 wind auction.
The Clean Energy Council stated that wind proponents in Australia:
...engage a range of stakeholders at early stages of
feasibility to determine environmental, cultural or amenity impacts in addition
to those identified in the formal environmental assessment process that need to
be understood and managed as part of the development.
These stakeholders include landowners; the local community;
experts in noise, landscape and visual impacts, aviation, electromagnetic
interference and heritage; the Civil Aviation Safety Authority (CASA); Network
Service Providers; electricity retailers; indigenous groups and other specific
interest groups including groups advocating in relation to local fauna or
The Clean Energy Council also highlighted several outstanding examples
of ongoing community engagement at Windlab's Coonooer Bridge wind farm and
Infigen's Flyers Creek wind farm. They noted:
The wind industry is not complacent about the strong
political and community support it receives and therefore continues to reflect
and innovate on the ways it interacts, engages and supports local communities.
A wind farm is part of a community for 20 years or more. History shows that
projects inject substantial direct and indirect economic benefits to these
communities both during the construction and ongoing operational phase of the
wind farm. The wind sector is continuing to explore and implement different
models for sharing the benefits these projects bring.
Infigen Energy reported on its engagement with local communities and
stated that it financially supports landowners to seek legal advice from a
practitioner of their own choosing before entering into agreements with the
Infigen Energy provides prospective landowners in their
development projects with extensive information on all aspects of wind farms,
answers any questions the landowners may have, offers tours of existing wind
farms, and encourages landowners to seek their own legal advice before signing
lease agreements. If the landowners desire it, Infigen Energy pays the full
cost of these legal services.
We are an industry leader that aims to fully inform
communities about operational and proposed wind farm sites. We contend that
empowering and informing the communities near our wind farms is one of the more
important issues facing the wind industry today. This applies equally to
neighbours to the project as well as the landowners hosting wind turbines.
With regard to the Flyers Creek wind farm development mentioned above,
Infigen Energy stated that it had initiated a community renewable energy cooperative,
which offers the local community the opportunity 'to invest in, and profit
from, the Flyers Creek wind farm after it is constructed.'
AGL outlined its approach to community engagement, including the
establishment of community consultative committees and the operation of
community funds, as follows:
AGL establishes Community Consultative Committees (CCCs)
early in the wind farm development process, which continue throughout the
development and construction phases. Once projects are operational, ongoing
community engagement takes various forms depending on the project, such as
continued CCC’s or the establishment of local renewable energy information
centres (as AGL has done at Burra, near the Hallett wind farms in South
Australia). AGL participates in regular CCC meetings in each of the communities
in which its wind farms are located or proposed.
The CCC brings together key representatives of the local
community to provide an opportunity to raise questions, voice concerns, build
relationships and to provide a forum for AGL to communicate with communities
about its operations. Local Council participation is essential in instilling
community confidence in wind energy and the planning process, and for all
projects AGL seeks to collaborate closely with local Councils which form a key
part of CCC deliberations. To balance community welfare and investor
confidence, AGL considers that robust Council and community engagement, such as
a CCC, should be a requirement of all wind energy project developments.
AGL also contributes to the communities neighbouring its wind
farm projects on an ongoing basis, and will do so for the life of the projects.
AGL is proud to contribute to the infrastructure and wellbeing of these
communities. For example, in the 12 months to June 2014:
The Macarthur Wind Farm Community Fund donated $50,000 to a range
of community organisations, including for sporting facilities, health equipment
and venue upgrades. An additional $40,000 was provided as a sponsorship for
local firefighting vehicles, and $12,500 in sponsorship was provided to local
students for educational travel.
The AGL Wattle Point Wind Farm Community Fund donated $15,000 to
local community, sporting and business groups.
The Hallett Wind Farm Community Fund donated $33,000 for local
health and conservation campaigns, and for the upgrade of community facilities
and sporting grounds.
AGL’s experience is that community contributions work well if
they are negotiated with local Councils or community groups to reflect their
RATCH-Australia reported a similar commitment to extensive community
engagement, including ensuring prospective turbine hosts are fully informed
before making any decisions:
As a developer of new wind farms, RAC has had dealings with
numerous private landholders who are prospective wind farm hosts. RAC is very
keen to ensure that any prospective hosts are able to make a fully informed
decision about hosting wind turbines, and has undertaken a range of
teaching/explaining activities for the prospective hosts, including:
Taking prospective hosts on tours of existing wind farms and
introducing them to other hosts and prospective hosts
Facilitating information sharing between prospective co-hosts,
making sure they are all talking to each other and sharing their thoughts and
concerns with the project group
Funding independent legal advice for prospective hosts on land
Funding independent expert reviews of studies we have undertaken
The Australian Wind Alliance reported:
Local matters around individual projects are routinely and
expertly handled by existing state and local planning processes.
The Australian Wind Alliance was, however, concerned that planning
processes, specifically public planning hearings, have been the subject of
disruption by anti-wind groups. It highlighted the case of a recent hearing
undertaken on the Crookwell 3 project in New South Wales, at which one of its
representatives had attempted to address the meeting but was 'verbally and then
physically intimidated by those in attendance', many of whom were not in fact
The committee also received evidence that state and territory
governments have been very active in updating their planning frameworks and in
developing tools to improve planning processes for both local communities and
Labor Senators note that the Clean Energy Council has also published the
Community Engagement Guidelines for the Australian Wind Industry. This
document was developed by the Australian Centre for Corporate Social Responsibility
and was sponsored by AGL, Acciona, Goldwind, Hydro Tasmania, Infigen, Pacific
Hydro, Vestas, RATCH-Australia and REpower.
The guidelines note that the full potential of wind farms to assist
Australia to meet its emissions reductions targets as well as to bring economic
benefits to local communities can only be realised with effective community
engagement. In order to encourage such engagement, the guidelines are:
...designed to be a blueprint for the Australian wind industry
to engage with those communities. It sets out the recommended steps to
delivering a wind farm project while maintaining the support and respect of the
Labor Senators encourage all wind farm proponents and operators to
implement these guidelines and also encourage state and territory jurisdictions
to consider codifying them in their respective planning regimes.
Labor Senators note that information presented to the committee on the
number of complaints made regarding wind farms indicates that very few people
have been motivated to take this course of action when compared to the size of
the populations that live in the vicinity of these developments.
As discussed under term of reference (c), Professor Simon Chapman has
undertaken research on the pattern of complaints about Australian wind farms on
the basis of noise or health effects and has demonstrated that 64.7 per cent of
all wind farms have never been the subject of any complaints, even though there
are an estimated 21,633 people living within five kilometres of these
facilities. This research also concluded that a total of only 129 individuals
had ever made a complaint, with 73 per cent of these complainants being
residents near six wind farms 'targeted by anti wind farm groups.'
The relatively small number of complaints, and their uneven distribution,
was recognised by the Victorian Department of Environment, Land, Water and
Planning which informed the committee that
Indications are that complaints about potential health impacts
appear to be related to a limited number of project sites..
That wind farms generate very few complaints from a very small minority
of residents was further confirmed by information provided by the Glenelg Shire
Council. The committee was informed that, of the approximately 11,000–12,000
residents living within a five kilometre radius of a wind farm in the Shire of
Council is aware of six people (from three families) who have
made written complaints about existing built wind farms. Further complaints
from two people were received about Stage 4 of the Portland Wind Farm prior to
Finally, Labor Senators note that the committee received some evidence
of dissatisfaction with the distribution of responsibilities between state and
local governments regarding the assessment of development applications and the
monitoring of planning conditions after a project is approved.
Labor Senators note that the difficulty in such cases appears to be that
local governments feel they lack the expertise and resources required to
properly assess wind proposals against the detailed technical requirements of
the planning regimes governing wind farms in each jurisdiction.
While noting that the delegation of planning responsibility to local
governments is a matter for each state jurisdiction, Labor Senators encourage
state governments to provide government bodies involved in their respective
planning regimes with sufficient resources to carry out their tasks, whether
they be at the state or local level, and to locate approval and monitoring tasks
with bodies best equipped to carry them out.
Labor Senators note that the Victorian Government has recently moved to
relieve local councils of the responsibility for determining planning permit
applications for wind farms and to make the Minister for Planning the decision
maker for all new permit applications.
The Queensland Government also submitted that it intends to change the
way wind farm developments are assessed. It noted that local governments are
currently the assessing authorities for wind farm developments against their
local planning schemes, however:
...the majority of planning schemes do not include specific
provisions for wind farms and many councils do not have the capacity or
resources to effectively assess these highly technical applications.
Future applications for wind farm development are to assessed
by the State Assessment and Referral Agency...
In conclusion, Labor Senators believe evidence provided to the committee
demonstrates that wind farm developments in Australia are currently subject to
very strict regulation, both when compared to other industries and when
compared to wind farm regulation in other countries. These regulations are
shaped, as they should be, by scientific and medical advice from the NHMRC.
Labor Senators emphasise that wind farms have generated a very low rate of
complaints to date and believe that the strict regulations in place have
contributed to this outcome.
Labor Senators also note that both state governments and wind farm
proponents are very aware of the important role community consultation plays in
the successful establishment of wind farms. Evidence before the committee
suggests that consultation is already extensive and that both proponents and
governments are working to improve processes wherever possible. Labor Senators
support this process of ongoing improvement and highlight the best practice
examples discussed above.
Labor Senators do not believe any case has been made for a wind farm‑specific
intervention in the land use planning regimes of the states and territories by
the Federal Government. The current arrangements are long-standing and
successful and the states and territories have demonstrated they are responding
where necessary to address pressures that arise from the technical nature of wind
farm planning assessments.
the adequacy of monitoring and compliance governance of wind farms
The 2012 report of the Senate Environment and Communications Legislation
Committee on the Renewable Energy (Electricity) Amendment (Excessive Noise from
Wind Farms) Bill 2012, found with regard to noise regulation of wind farms:
The committee has seen evidence of adequate compliance
mechanisms and audit processes in place, and acknowledges the work of state
governments in strengthening aspects of these processes over the last three
Labor Senators do not believe any significant areas of concern have
arisen since this time. Evidence presented to this inquiry suggests monitoring
and compliance mechanisms with regard to noise and other aspects of wind farms
are being effectively managed by state and territory bodies.
The Department of the Environment noted that primary responsibility of
monitoring and compliance of wind farms falls to the states and territories,
but that the Commonwealth has a limited role in monitoring projects that have
been approved under the Environment Protection and Biodiversity Conservation
Act 1999 (EPBC Act). These activities are determined by the department's
Annual Monitoring and Compliance Plan, and cover only those activities relevant
to the EPBC Act.
As detailed in discussion under term of reference (b), the CER monitors
compliance of wind farms with Commonwealth, state and territory regulations,
but does not itself make determinations about compliance.
The Clean Energy Council summarised the monitoring and compliance
requirements currently affecting wind farm developers and operators as follows:
Wind farm projects adhere to specific technical compliance
regulations. In order to apply for a development permit the wind farm developer
must undertake various technical measurement, analysis and modeling and submit
it for approval. Once approved, wind farm owners are required to supply further
information to the regulator (usually the state government) which has experts
who undertake the compliance analysis.
The South Australian Government submitted that it believes the wind farm
industry is well regulated and that it has only found one case of marginal
non-compliance in the 12-year history of the industry, a matter which was
rectified promptly by the operator:
In South Australia, a wind farm developer needs to abide with
specific compliance hurdles in order to be operational, and these requirements
have led to a well regulated industry. Compliance is required for a change in
land use, connection to the grid, generation, and noise.
Planning approval is required for a change in land use, which
includes compliance with the EPA noise guidelines. Before developing the site,
the proponent is typically required to monitor background noise. Once
commissioned, further monitoring is required to ensure the wind farm operates
within the noise guidelines.
This system is proven to be sufficiently robust. During 12
years of wind industry history in South Australia, there was only one case of
marginal non-compliance linked to the temporary presence of tones in wind farm
noise. This issue was rectified by the wind farm owner in an efficient and
The Victorian Department of Economic Development, Jobs, Transport and
Resources noted that the compliance of wind farms with noise standards
attracted the most interest. In Victoria planning approvals require new wind
farms to meet New Zealand Standard 6808:2010, Acoustics – Wind Farm Noise, and
older wind farms to meet the 1998 version of this standard. The department
provided the following details about compliance processes:
Planning permit conditions require operators to undertake
monitoring and demonstrate compliance with the New Zealand Standard following
completion of construction. The specific conditions of each permit vary in
their wording but generally a final compliance report must be submitted after a
12 month testing period following the commencement of full operation of a
facility. These reports can be peer reviewed by the responsible authority.
Following this review, if the facility is deemed to be operating in accordance
with the permit requirements regarding noise, the responsible authority will
advise the proponent.
All wind farm permits require the proponent to develop a
noise complaints evaluation procedure to address complaints or possible noise
compliance issues. When the model permit conditions from DELWP’s guidelines are
used, they include provisions where the responsible authority can require the
initiation of additional noise testing at the cost of the wind farm operator.
The Victorian Government has been refining the wind farm
guidelines and the model wind farm permit conditions since their introduction.
Some older permits for wind farms do not have the ability to compel operators
to undertake further testing. In these instances further acoustic testing could
be undertaken by the council if warranted to address specific issues or
The draft NSW Planning Guidelines: Wind Farms indicate that
similar requirements are placed on wind farms developers in that state:
A number of requirements will be applied regarding auditing
and compliance particularly in relation to noise including:
Conditions of consent will require the applicant to prepare and
submit a Noise Compliance Report within 12 months of the commencement of
operation of the wind farm
Noise monitoring must be undertaken during ‘worst case’ periods
(which would include during any temperature inversions).
Special audible characteristics such as excessive amplitude
modulation (including the van den Berg effect) together with cumulative impacts
must also be considered.
The proponent must make the noise compliance report publicly
Neighbour can write to the Director General of the Department of
Planning and Infrastructure to request independent noise monitoring at their
In response to complaints from residents about noise and other issues
the New South Wales Government has conducted a compliance audit of wind farms.
This audit was completed in 2013 and included the Cullerin Range, Capital and
Woodlawn wind farms. This audit included an independent acoustic expert taking
measurements at nearby residential properties. The audit concluded that 'all
three wind farms were compliant with their noise-related approval conditions.'
The audit did identify breaches of a number of other conditions which have
since been rectified by operators.
The South Australian Environment Protection Authority has also conducted
additional studies to address concerns of residents regarding sound emissions
from wind farms, despite such farms demonstrating compliance with their
development approval conditions via the standard post-construction noise
Mr Peter Dolan of the South Australian Environment Protection Authority
described the work his organisation undertook to investigate the sound
emissions of the Waterloo wind farm in response to repeated complaints:
We did an extensive study at Waterloo over two months in six
houses from zero to 20,000 hertz. We investigated this in detail because a
group of concerned citizens came to us and convinced me that we needed to do
more work to understand this. We were able to arrange for six shutdowns of the
complete station whilst our equipment was still running during periods of generation—so
what we would consider peak times for noise generation. We did however select
the sites that we monitored based on complaints—there were folk who had
complained previously about the wind farm—and that was based on the assumption
that if that is truly concerning them we should be able to find something. We
did not. In fact, I was quite surprised at how certain the results were. At
several of the sites the wind farm was not detectable at all.
At several sites residents who had filled out a diary for us
recorded concerns about the wind farm when the wind farm was most definitely
off. We continuously monitored throughout the period of the shutdown, before
and after, and we made sure that we only used data where we had had operating
machines going for at least two hours prior to and two hours after to see what
contribution the wind farm made to entire spectrum, including infrasound. They
clearly contribute but at no time did they exceed the South Australian
guidelines during that period. In some sites you could not notice the
difference in noise or sound whether the wind farm was operating or not. So,
based on that study, we do not believe there is a need to change our
guidelines, other than some tidy up.
Pacific Hydro provided the following summary of compliance measures wind
farm developers must meet:
Approval of a wind farm requires that a wind farm developer
prepare in-depth technical measurements, analysis and modelling which must be
approved by the relevant regulator(s). Following the granting of an approval,
the wind farm operator must ensure compliance with the various conditions of
the approval, which includes the ongoing provision of technical measurements
and analysis to regulators, who undertake compliance analysis.
Labor Senators note that some wind farm operators have undertaken
studies beyond those required under planning regulations in order to address
community concerns. A prominent example of such work is the study conducted by
Mr Steven Cooper at Pacific Hydro's Cape Bridgewater wind farm. This study was
commissioned by Pacific Hydro in order to investigate disturbances reported by
residents in three households.
As discussed under term of reference (c), the author of this report
agreed with the operator that the report did not justify any change to the
regulatory regime. Labor Senators also note that the Cape Bridgewater facility
has already been found to comply with its permit conditions and applaud Pacific
Hydro for its efforts in investigating this matter further.
The inquiry also received evidence of wind farm operators carrying out
ongoing bird and bat monitoring at their wind farms. For example, Trustpower
provided the following information on its Snowtown wind farm:
Trustpower has a contractual requirement with our services
providers that manages the respective Stage 1 and Stage 2 of our Snowtown Wind
Farm to look for and report any bird strikes. We also had a specific annual
Wedge Tail Eagle nesting monitoring plan for both stages of the wind farm,
which has now been completed. The monitoring programme has identified
successful annual wedge tail eagle breeding on site during the construction and
operating of the wind farms and a total of 2 wedge tail eagle mortalities since
commencement of operation in 2008.
AGL also stated that it undertakes regular monitoring of bat and bird
mortality at its wind farms, and provided the following information regarding
the Macarthur wind farm:
Where required by planning permits, AGL undertakes monitoring
programs to estimate the frequency of bird and bat deaths as a result of
collision with wind turbines. In the first 12 months of monitoring at the
Macarthur Wind Farm, an estimated mortality rate of 1.3 birds per turbine per
year was observed, as well as 0.1 bats per turbine per year. Importantly, the
effects on threatened species were found to be negligible, and no collisions
with the primary avian species of concern at the site (brolga) were observed.
Labor Senators believe that evidence presented to the committee
indicates that state and territory governments have implemented effective
regimes for undertaking monitoring and enforcing compliance.
With regard to the issue of compliance with noise limits imposed by
planning regimes, it appears state bodies have been very active in responding to
community concerns. In addition to the post construction noise monitoring that
takes place at each wind farm development, state bodies such as the NSW
Department of Planning and Infrastructure and the South Australian Environment
Protection Authority have undertaken further investigations where repeated
complaints have been received. In these cases, the wind farms have again been
found to be compliant.
Labor Senators do not believe any case has been made that the compliance
and monitoring regimes of the states and territories are systemically flawed.
As discussed under term of reference (d) the distribution of
responsibilities and resources between state and local governments may be a
point of weakness in current arrangements. The Australian Wind Alliance noted a
number of matters with regard to compliance monitoring that could be addressed
in future reforms:
Compliance of wind farms with applicable regulations is in
many cases devolved to the local council level, who are often under resourced
and lack the appropriate skill base to execute this work properly.
Postconstruction noise monitoring is generally done by
acoustic consultants retained by the developer. Submission 111 to this Inquiry
from Glenelg Shire Council has suggested that postconstruction and ongoing
monitoring work be done at arms’ length from developers.
AWA sees merit in this idea and would welcome it as a way to
increase the community’s trust in the process.
Labor Senators recognise the very significant resource pressures facing
local councils and the additional cost burden imposed when they are forced to
retain outside expertise to inform decision making and to conduct monitoring
and compliance work. Labor Senators encourage state governments to work with
councils to determine the best way to reduce these pressures. The committee
heard evidence from the Municipal Association of Victoria that it is currently
negotiating to gain access to the acoustic expertise of the EPA.
Labor Senators applaud this work and encourage further collaboration of this
Labor Senators do not question the professionalism, nor the quality, of
advice that has been provided by acoustic consulting firms that have worked on
post-construction and ongoing compliance work to date. The weight of evidence
provided to the committee is that there has been no impact on the independence
of the work completed or the advice provided. However, Labor Senators recognise
that the perception of independence within the community is also important and
note that change in this area may serve to ease concerns that some individuals
may have and instil broader community confidence in the system.
the application and integrity of national wind farm guidelines
Labor Senators note that, as there are currently no national wind farm
guidelines in place, it is not possible to comment on their application or
integrity. A document entitled National Wind Farm Development
Guidelines–draft does exist, but it has never progressed beyond the draft
stage. The history of this draft document is outlined below.
Dr Prest of the Centre for Environmental Law submitted that Commonwealth
regulation of wind farm projects was first suggested in 2006 by former
Environment Minister, Senator Ian Campbell, in the form of a 'code of practice
for wind projects', as a means of justifying 'intervention in local planning
matters in the proposals for wind farms at Denmark (WA) and Bald Hills (Vic).'
The code of practice was replaced by the idea of a set of guidelines,
following a change of government at the federal level. These guidelines were
developed by the Environment Protection and Heritage Council (EPHC), a body
established by COAG to address national policy issues regarding environmental
protection. As noted by Dr Prest, a 2008 report by the EPHC, Impediments to Environmentally
and Socially Responsible Wind Farm Development, included the following
rationale for national guidelines:
The Working Group agreed that the assessment and approval
systems in jurisdictions are generally robust and working well, and that many
issues identified in this report are being adequately dealt with through
However, the Working Group concluded that there is merit in
developing government-endorsed National Wind Farm Development Guidelines to
deliver a higher degree of consistency and transparency in the planning,
assessment, approval and environmental monitoring of wind farms. These
Guidelines would assist in building community acceptance and support for wind
This report also noted that the best practice model embodied by the
guidelines 'is preferred because it can provide greater national consistency in
how the matters it covers are addressed and can be readily incorporated into
jurisdictions' existing regulatory practice without the need for amendments to
statutory schemes.' The previous code proposal was considered the 'less
preferred approach because it would be viewed as having its own legal basis and
the working group does not believe there is a compelling rationale for a
mandatory approach, ie, the existing regulatory arrangements are effective.'
In 2009 the EPHC directed officials to develop such national wind farm
development guidelines, a draft version of which was released for public
consultation in July 2010. The Department of the Environment described the
content and intended use of these guidelines:
The draft Guidelines outlined best-practice for industry and
planning authorities, promoting a higher degree of consistency and transparency
in the planning, assessment, approval and monitoring of wind farms across
jurisdictions. The draft Guidelines included key principles for consideration,
addressing a range of issues which are unique or significant to wind farm
development and operation: community and stakeholder consultation; wind turbine
noise; visual and landscape impacts; impact on birds and bats; shadow flicker;
and electromagnetic interference. The draft Guidelines were not mandatory, nor
did they seek to change existing jurisdictional statutory processes.
The EPHC ceased further development of the draft guidelines because
jurisdictions did not consider them necessary and stakeholders believed that
they 'added complexity and involved the Commonwealth in an area for which it
was not the responsible authority.'
The 2011 Senate Community Affairs References Committee inquiry into the
social and economic impact of rural wind farms recommended that the draft
guidelines be updated.
The then federal government did not act on this recommendation, having decided
that the draft guidelines remained unnecessary.
No further work has taken place on these draft guidelines since 2011.
The Clean Energy Council stated in its submission that national
guidelines are not needed as each jurisdiction has guidelines adapted to their
Every Australian state government has planning guidelines
that are best suited to the unique requirements of its community, industry, and
land use configurations. Planning rules for wind farms (and for any other major
project) must simultaneously consider various technical issues and social
issues. State governments should be left to design wind farm planning
requirements as a part of a broader planning regime.
The South Australian Government expressed a similar view and commented
on the last iteration of the draft guidelines:
The South Australian Government is not supportive of national
wind farm guidelines due to the particular nature of each state, and the
individual differences in planning system regimes. The latest version of the
Draft National Wind Farm Guidelines included controversial recommendations
which South Australia did not support and further work on the Guidelines was
stalled due to a change of priorities at the Federal level.
The Victorian Department of Economic Development, Jobs, Transport and
Resources expressed a more positive view on the draft guidelines and noted some
areas where further refinements might be made, but also emphasised their status
as a useful resource rather than a mandatory requirement:
The draft national wind farm guidelines are a useful resource
for developers, decision makers and communities. The guidelines acknowledge
that each state has its own planning controls and regulation. They provide
detailed information on the matters considered when determining permit
applications. The guidelines are referenced in the Victorian wind farm
The Victorian Government considers the national guidelines to
be an appropriate tool having regard to Victorian legislation. Further
refinements may be considered with regard to the 1 km consent zone around
turbines, EPA auditors, and enforcement.
Labor Senators note that the project to develop national guidelines was
undertaken on the explicit basis that they were not intended to have a legal
status in their own right and that they were not intended to require amendments
to statutory schemes. These guidelines have remained in draft form and,
although some jurisdictions have found them useful, others disagree with their
content and do not support their further development.
Labor Senators note that the proposal put forward in recommendation 3 of
the committee's interim report effectively calls for a return to the mandatory
'code of practice' approach first raised in 2006. By supporting this approach,
the committee majority has in effect called for a Commonwealth takeover of
planning and environment regulation governing wind farms. This recommendation
states that revived national wind farm guidelines should be codified by the
Commonwealth and that state and territory jurisdictions should alter their
planning and environment statutes to conform with them.
No case has been made that state and territory planning regimes are not
adequately addressing the development and operation of wind farms. In fact, the
opposite appears to be true, with evidence suggesting that a very small
proportion of the population living in proximity to wind farms have ever
registered complaints and that state jurisdictions have been actively updating
planning arrangements and producing best-practice guidelines in the period
since the national wind farm guidelines project was abandoned. As argued under
term of reference (d), Labor Senators strongly oppose this attempt to impose
additional levels of federal regulation on a specific industry.
While Labor Senators note that the committee has listed in its interim
report a number of matters on which the proposed new national guidelines must
set minimum standards, it has made no comment on how these standards will be
formulated, nor any specific comment on how current regulation of these areas
is failing. It is therefore unclear how these guidelines are expected to differ
from those currently in place in each jurisdiction and, if they are to differ,
on the basis of what evidence and advice this will be determined.
Finally, Labor Senators note that media reports indicate that, despite
this committee not yet delivering its final report, the federal government has
already made an attempt to introduce a national wind farm sound measure in the Environment
Protection and Heritage Council Act 1994, and to implement new national
wind farm guidelines that include minimum standards.
These proposals were reportedly put to a meeting of Commonwealth, state
and territory environment ministers on 14 July 2015, but were rejected by state
ministers. It was reported that:
...the states rejected the measures. State ministers asked Hunt
four times if he planned to impose the same guidelines for coal, but he said no
One of the states also attempted to have the details of the
rejection of the wind farm sound measures included in the communique, but the
federal government kiboshed the attempt.
A spokesperson for Hunt did not respond to Crikey’s
questions by deadline.
A spokesperson for Victorian Environment Minister Lisa
Neville told Crikey in a statement that the push was rejected by the
states because the concerns raised by the Senate inquiry had been "widely
rejected by scientific and medical opinion".
"The opened proposal wanted minimum standards dealing
with compliance obligations, turbine noise, and more regulations regarding
consultation. Victoria opposed these changes," the spokesperson said.
Labor Senators are also firmly of the view that there is no compelling
case for Commonwealth intervention in this area. Criticism of current
arrangements stems overwhelmingly from those who accept claims of negative
health and environmental impacts that have been repeatedly demonstrated to have
no scientific foundation.
the effect that wind towers have on fauna and aerial operations around
turbines, including firefighting and crop management
Labor Senators note that any development activity will have some impact
on fauna. Wind farms are no exception to this general rule. However, evidence
presented to the committee demonstrates that the impact of wind farms on birds
and other animals is extremely small when compared to that of other human
activities and that any impacts are generally the subject of considerable
scrutiny and mitigation activity, both prior to and after construction.
The regulation of environmental impacts for wind farm developments is
primarily managed at the state level. However, the federal government also
plays a regulatory role in cases where a development will have or is likely to
have an impact on a matter of national environmental significance. In such
cases, the approval of the Minister for the Environment is required under the
The Clean Energy Council provided the following summary of how wind farm
developers and operators address the environmental impacts of their projects:
Before a wind farm is constructed, project proponents conduct
extensive surveys over a number of years to assess the potential impact a
particular wind farm could have on surrounding flora, vegetation, soil and
fauna, including birds and bats. Many wind farm operators are required to
implement a monitoring program during key times such as migration or breeding
to oversee potential issues.
If threatened or endangered birds and bat species live around
or migrate through a wind farm, very stringent regulation applies to ensure
that any impacts are minimal. During wind farm design, detailed mitigation and
monitoring measures are utilised to minimise the impact on fauna species
surrounding the site.
Bird and bat monitoring after construction is becoming
routine practise both in Australia and overseas. There are no consistent
standards in Australia for undertaking monitoring and most plans are developed
with consultants and local regulators as part of the bat and avifauna management
(BAM) plan for the wind farm.
The committee was presented with evidence to the effect that bird deaths
attributable to wind farms form an extremely small proportion of overall bird
deaths resulting from human activity. Several submissions cited published
estimates that wind turbines account for fewer than 1 in 10,000 bird deaths
from anthropogenic causes, with buildings, power lines, cats, vehicles and
pesticides posing far greater risks.
Environment Victoria highlighted two further sources of information from
North America. The 2014 State of the Birds report attributed 250,000 bird
deaths per year to wind turbines in comparison to 2.6 billion attributed to
cats and 620 million attributed to collisions with buildings. A further
comparison of deaths caused by wind turbines and deaths caused by other
electricity generation sources found 'coal-fired power stations are responsible
for 35 times more bird deaths than wind turbines. Coal is responsible for 42%
of US electricity generation, with all renewables at 12%, so the discrepancy in
mortality is not a function of how much more coal power there is.'
The South Australian Government confirmed that wind farm proponents must
conduct surveys to ascertain any possible impacts on flora and fauna prior to
gaining planning approval and that the proposal must be modified to ensure
there are no significant impacts on any identified threatened species under the
EPBC Act. It also provided the following figures on bird mortality per gigawatt
hour for various forms of electricity generation:
There are incidences of bird strike at wind farms, although
some wind farms do not incur bird kills and modern wind turbines operate in low
rotation speed modes thereby mitigating bird strike. This information, however,
needs to be put in context and compared with other forms of electricity
generation. A 2013 study estimated the number of birds killed per gigawatt hour
(GWh) of generated wind electricity, fossil fuel and nuclear power systems. The
study estimates that wind farms and nuclear power stations are responsible each
for between 0.3 and 0.4 fatalities per GWh of electricity, while fossil fuelled
power stations are responsible for about 5.2 fatalities per GWh.
Labor Senators note that bird mortality rates at wind farms are
established with greater accuracy than for other industries due to the greater
levels of investigation undertaken by wind farm operators. As Ms Bennett, an
independent consultant specialising in wind farm bird and bat mortality
Wind turbines are not unique in their impact on birds.
Powerlines, roads, buildings, aeroplanes, cats, foxes, radio towers,
pesticides, land use change, climate change and many other things are all
negative pressures facing bird survival, and if we want to understand the
impact our society has on birds then we need to understand each of these
components and how they interact together to threaten species survival. Wind
farm operators are doing their bit to understand their impact, but without a
holistic approach by all industries the actual impact to the population is
difficult to estimate.
Concerns over the impact of wind farm developments on the brolga, which
is listed as a threated species in Victoria but not in other Australian states
nor under the EPBC Act, were raised with the committee by the Brolga Recovery
The group suggested that established and proposed wind farm developments across
south west Victoria are having and will have a damaging impact on brolga
populations. In particular the group argued that a recent bird utilisation
study conducted at AGL's Macarthur wind farm demonstrated that 'Brolga are
absent when turbines are operating at greater than 30% of capacity.'
However, Labor Senators note Ms Bennett's statement that, in her 10
years of experience undertaking bird mortality surveys, 'the only time I found
a dead brolga was in my capacity as a Landcare facilitator, where one of my
volunteers phoned me up because they had found a dead brolga next to a wildlife
reserve under powerlines.'
Mrs Susan Dennis, President of the Brolga Recovery Group, was not able to
produce any concrete evidence of any recorded brolga deaths due to wind farms,
but had also witnessed brolgas hitting power lines.
Evidence provided by AGL on brolga monitoring at the Macarthur wind farm
contradicts the Brolga Recovery Group's claims:
Where required by planning permits, AGL undertakes monitoring
programs to estimate the frequency of bird and bat deaths as a result of
collision with wind turbines. In the first 12 months of monitoring at the
Macarthur Wind Farm, an estimated mortality rate of 1.3 birds per turbine per
year was observed, as well as 0.1 bats per turbine per year. Importantly, the
effects on threatened species were found to be negligible, and no collisions
with the primary avian species of concern at the site (brolga) were observed.
Ms Bennett, who has conducted or supervised over 8,000 bird and bat
mortality surveys at eight separate wind facilities, stated that such
facilities have only a minor impact on the brolga:
...population decline has been primarily due to loss of
habitat, coupled with predation of chicks by foxes. Collision with powerlines
is an unknown factor but a real threat to large birds. Wind farms will add
another pressure to the declining brolga populations. However, by contrast this
is relatively minor in view of those factors which have led to species decline.
With regard to the Macarthur wind farm, Ms Bennett stated:
Arguments about brolga displacement from wind farms are not
supported by the evidence that has been collected. At Macarthur Wind Farm
brolgas have been recorded breeding within 200 metres of a turbine and grazing
within 100 metres of a turbine. At Mortons Lane Wind Farm a solitary brolga is
a regular visitor to the paddock adjacent to the substation and within 200
metres of a turbine. There is also a natural flocking site that has remained
undisturbed less than three kilometres away.
Ms Bennett also commented on the ability of birds to learn to avoid wind
farms, such that their impact reduces over time:
There is lots of evidence all around the world about birds'
behaviour and avoidance. That is shown through data where we may find an
initial impact in the first month of operation which drops off significantly
straight away and throughout the life of the wind farm. We have not done
extensive long-term studies here in Australia, but there is certainly a lot of
evidence, particularly with small wind farms such as the Hepburn wind farm,
where we found no birds during our mortality monitoring at all. Small wind
farms have clear avoidance patterns; that has been demonstrated. I would suggest
that birds are not stupid.
Labor Senators believe, based on evidence put before the committee, that
wind farms in fact have a very limited impact on fauna, and on birds in
particular, both in relative and absolute terms. While any negative impacts on
wildlife are regrettable, evidence suggests that wind farm operators are better
informed about, and more proactively responsive to, this side effect of their
activities than are other industries.
On the particular issue of the interaction of brolgas and wind farms in
south‑west Victoria, Labor Senators do not believe any expert evidence
was presented to the committee that recent wind farm development has had a
significant impact on population levels.
With regard to aerial firefighting operations, the committee received no
credible evidence that wind farms, when appropriately managed, pose greater
risks than any other structures or have hampered the operations of rural
firefighters. In fact the committee received evidence that wind farms have in
some cases aided firefighting operations because they offer improved access for
The New South Wales Rural Fire Service informed the committee that 'a
fire moving across the area of a wind farm is generally managed in the same way
as any other grass and/or bushfire.'
It further noted that, although 'aerial firefighting suppression in close
proximity to wind turbines may be inhibited at times' this is because
firefighting aircraft operate under the Civil Aviation Safety Authority's
(CASA) Visual Flight Rules for navigating by visual reference and are
required to maintain standard distances from wind turbines, as they are with
'any other potential hazard such as power lines, transmission towers, mountains
A position statement developed by the Australasian Fire and Emergency
Services Authorities Council emphasises that the risks posed by wind farms are
routine and no greater than those posed by other activities:
Wind farms are an infrastructure development that must be
considered in the preparation of Incident Action Plans for the suppression of
bushfires in their vicinity. These considerations are routine and wind farms
are not expected to present elevated risks to operations compared to other
Aerial fire fighting operations will treat the turbine towers
similar to other tall obstacles. Pilots and Air Operations Managers will assess
these risks as part of routine procedures. Risks due to wake turbulence and the
moving blades should also be considered. Wind turbines are not expected to pose
Wind farms are not expected to adversely affect fire
behaviour in their vicinity. Local wind speeds and direction are already highly
variable across landscapes affected by turbulence from ridge lines, tall trees
Turbine towers are not expected to start fires by attracting
Turbines can malfunction and start fires within the unit.
Automatic shutdown and isolation procedures are installed within the system.
Although such fires may start a grass fires within the wind farm, planning for
access and fire breaks can reduce the likelihood of the fire leaving the
property. This risk from such fires is less than that of many other activities
expected in these rural environments.
An example of the high level of fire safety precautions taken by wind
turbine manufacturers and operators was provided by Pacific Hydro, who outlined
the following measures present at their Cape Bridgewater wind farm:
All major components within the wind turbine are fitted with
temperature sensors. These sensors ensure turbines are closely monitored (24
hours a day) to ensure they remain within their designed operating range. If
any of the settings are exceeded (e.g. because of fire, overheating, smoke),
the turbine controller automatically shuts down the turbine and sends an alarm,
via the control system, to a technician. Following a detailed inspection of the
systems which caused the particular fault, the turbine will then be restarted
Fire extinguishers are fitted in every turbine in the nacelle and
at the entrance in order to comply with the relevant Australian Standards and
Pacific Hydro’s operating procedures, emergency
evacuation/management procedures and up to date training of all personnel
ensures that all operating and safety measures are adhered to.
All vehicles entering the wind farm site must use diesel fuel and
be fitted with fire extinguishers.
Site personnel are equipped with the latest radio communication.
The Victorian Country Fire Authority stated that it provides advice to
owners and operators of wind farms and advice on planning permit applications.
It has developed the Emergency Management Guidelines for Wind Energy
Facilities, which provide guidance to operators on such matters as
engagement with the CFA, siting of turbines, access recommendations and
provision of firefighting water.
When asked whether wind turbines are particularly problematic for
firefighters, the Victorian Country Fire Authority stated:
No. We have done an investigation of fire and incident
reporting data over the last 17 years—so, back to 1998—and we have had 289
incidents in areas surrounding wind farms, none of them involving the wind farm
facility as such. As you say, there are a lot of other risks within the natural
environment rather than the towers themselves. From my perspective, from an
operational perspective, we would rate trees themselves as being one of the
highest risks to firefighters for injury and death over wind farms or wind
With regard to aerial operations in particular, the committee was
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 Australian Wind Alliance confirmed the advice of the Victorian
Country Fire Authority that wind turbines are treated much like any other
obstacle, and also noted that wind farms have a beneficial impact on firefighting
Advice to AWA confirms the position of the Victorian CFA.
Furthermore we have received advice that wind farms actually improve
accessibility for fire intervention due to the proliferation of well maintained
access roads and the presence of onsite staff who are alert to fire threats.
Trustpower informed the committee that access tracks built for stage 2
of its Snowtown wind farm improved access for the local CFS and acted as a fire
break during recent grassfires. They quoted the local Snowtown CFS captain's
comments regarding the access roads:
They were absolutely of great benefit in helping us fight the
fires. If it weren't for those roads the fires, which were going at a fair rate
of knots, would have just kept going. They acted as a natural fire break,
giving us an edge to work back to and enabling us to back burn if we'd needed
to. These new access roads provided an unexpected bonus, but they'll help us
control fires in the future.
The committee received advice from CASA that it had not identified any
aviation accidents resulting from wind turbines:
The data that CASA has readily available in the timeframe is
derived from Aviation Safety Incident Reports from 2008 to the present. In that
period CASA has not found any aviation accidents related wind farms or wind
turbines. For the same period there 1,231, aviation accidents.
The committee received several submissions raising concerns about the
impact of the Gullen Range Wind Farm on the operations of the Crookwell
Labor Senators note correspondence from CASA in response to these submissions,
which noted that it had been consulted on the original planning application for
the wind farm and that NSW Planning had, consistent with the current National
Airports Safeguarding Framework, deleted 11 proposed turbines that 'would have
been within the boundary of the hypothetical obstacle limitation surfaces (OLS)
for a local, daylight-only, non-instrument runway such as Crookwell.' There
will now be 'no infringement of the theoretical OLS which have an extent of
3,600m from the aerodrome.'
CASA has also examined safety issues in light of correspondence on the
matter and concluded:
That the wind turbines would not be hazardous obstacles for
operations at Crookwell aerodrome provided pilots are above the required
minimum altitudes for day and night operations. The wind turbines present a
pilot with conditions that their training equips them to deal with. In this
context CASA agrees with the view expressed by the NSW Rural Fire Service
(Submission 97) that wind turbines are not expected to pose increased risks due
to wind turbulence or rotating blades. The NSW Rural Fire Service notes pilots
are required to maintain standard distances from wind turbines, just as they
are from other potential hazards such as power lines, transmission towers,
mountains and valleys.
With respect to the issue of turbulence, CASA's response also noted that
the '3,600m exclusion zone mandated by the NSW Government should ensure that
excessive turbulence from the rotors is not experienced in the immediate
vicinity of the aerodrome' and that the aerodrome is already subject to
warnings regarding natural wind effects due to the Gullen Range itself.
Finally, Labor Senators note the concern raised by the Aerial
Agricultural Association of Australia (AAAA) regarding the safety threat posed
by wind farm developments to low-level aviation.
In general, as noted by the Clean Energy Council, Labor Senators agree with the
Clean Energy Council that, 'Wind turbines are just another obstacle to be
managed in planning and conducting low level aerial operations. It is the
responsibility of the pilot to anticipate, assess and make operational
judgments as to how close they fly to an obstacle.'
As noted by Vestas, the US state of Iowa provides an example of the very
productive coexistence of the cropping and wind power industries:
From the 2007 Census to the 2012 Census, Iowa’s total value
of agriculture production increased 51 percent. The value of crops sold also
increased by 69 percent, and the value of Iowa livestock production increased
by 34 percent.
Iowa is also the third-biggest producer of wind power in the
USA. The wind industry has grown in Iowa to create between 6000 and 7000 direct
and indirect jobs, with an installed capacity of almost 6000 MW of wind power
(significantly more than all of Australia’s installed wind capacity). The wind
industry in Iowa has attracted around US $10 billion of capital investment.
In Iowa the wind industry and the cropping industry have
learnt to co-exist and do so in a safe and profitable manner. Accordingly we see
no reason why Australia is any different.
In the specific case of wind monitoring towers, which are often
associated with wind farm developments and can be very difficult for pilots to
see, Labor Senators agree that high visibility marking is essential. This
matter is covered at section 39 of the National Airports Safeguarding Framework
Guideline D, and Labor Senators urge wind farm operators to ensure they
implement the measures suggested there.
the energy and emission input and output equations from whole-of-life
operation of wind turbines
Evidence presented to the committee unequivocally demonstrates that wind
turbines rapidly generate more energy than is used in their whole-of-life
operation, including construction, installation, operation and decommissioning,
and that wind turbines produce among the lowest emissions per unit of
electrical energy of all generation types.
With regard to the greenhouse gas emissions intensity of wind farms, the
Energy Supply Association of Australia referred to a recent analysis conducted
by the US National Renewable Energy Laboratory, which concluded that the
greenhouse emissions generated by wind farms are dwarfed by those of coal or
gas fired power plants:
...the median published life cycle greenhouse gas emission estimates
for onshore wind farms is 12 grams of carbon dioxide equivalent CO2-e
for each kWh of electricity generated (gCO2-e/kWh). In contrast,
coal-fired power plants emit 979 gCO2-e/kWh on average. This varies
significantly depending on the type of coal used and the type of generation
technology. Gas-fired power plants emit between 450 (combined cycle) and 670
gCO2-e/kWh (open cycle).
The IPCC has also published figures on this matter in its 2014 Mitigation
of Climate Change report. Its findings on this topic were summarised by
RATCH-Australia Corporation as follows:
Median lifecycle emissions from a coal-fired power station are
820 grams of carbon dioxide-equivalent emissions per kilowatt hour of
electricity generated (820 gCO2eq/kWh).
Median lifecycle emissions from a combined cycle gas power
station are 490 gCO2eq/kWh.
Median lifecycle emissions from an onshore wind farm are 11 gCO2eq/kWh.
Siemens has recently published calculations that indicate one of its
turbine models has an energy payback period of 4.5 months.
Vestas informed the committee that each of its turbines generates over 25 times
the energy consumed during its lifecycle.
Further, in documentation published by the New South Wales Department of
Environment, Climate Change and Water, it has been estimated that wind farms
'typically generate the energy used in construction within three to seven
months of operation, with the operational lifetime of a turbine being at least
Based on these figures, it is clear that wind farms emit a small
fraction of the greenhouse gasses generated by coal and gas power stations. It
is also clear that they very quickly recover the energy used in their
production and installation.
The level of greenhouse gas abatement achieved depends on which type of generation
wind power is displacing. This matter was explained by AGL:
Under the design of the National Electricity Market (NEM),
generators bid their capacity into the market, and the market operator (AEMO)
is responsible for dispatching the lowest-cost capacity to meet demand for each
half hour interval of the day. Wind farms tend to have low operating costs, so
generally can bid in their generation capacity at a low price, and are
therefore dispatched ahead of generators with higher operating costs (such as
gas or coal).
The amount of greenhouse gas emissions avoided via the
operation of wind farms at any given time depends on the emissions intensity of
the ‘marginal’ generator(s) that would otherwise have been dispatched to meet
electricity demand, which may produce more or less emissions per unit of
electricity generated than the market average depending on the fuel and age of
the power station.
The Department of the Environment summarised the findings of recent
modelling undertaken for the Warburton Review of the RET scheme by ACIL Allen
to calculate emissions abatement. Although this modelling is based on a target
which has since been reduced, it remains instructive:
The modelling estimates that 50 to 60 per cent of the
additional renewable electricity generated displaces black goal generation,
while brown coal and baseload gas make up around 20 per cent each of the
electricity generation displaced. Hydro and peaking gas generation is also
slightly reduced in many years.
The modelling indicates this decrease in electricity
generation from black coal, brown coal and gas would reduce emissions by 59 Mt
CO2-e between 2015 and 2020, and 299 Mt CO2-e between
2015 and 2030.
With regard to the level of abatement achieved to date under the RET,
the Warburton Review itself noted:
Historical CO2-e emissions abatement from the RET
has been estimated by SKM to be around 20 Mt CO2-e between 2001 and
2012. The modest level of abatement achieved to date primarily reflects the
small targets in effect under the scheme from 2001 to 2009.
The Warburton Review also referred to a body of modelling work on the
significant increase in greenhouse emissions that would occur were the RET to
Bloomberg New Energy Finance estimates that removing the RET
would increase cumulative emissions from the power sector by 57.3 Mt CO2-e
over the period 2015 to 2020 and 259 Mt CO2-e over the period 2015
to 2030. Modelling by ROAM Consulting for the Clean Energy Council found that
cumulative emissions would be 34.7 Mt CO2-e higher by 2019-20 if the
RET is repealed and modelling by Schneider Electric suggests that removing the
LRET would increase cumulative emissions in the National Electricity Market by
around 50 Mt CO2-e by 2020 and by 260 Mt CO2-e by 2030.
Labor Senators note that the overall emissions intensity of electricity
generation in the NEM has fallen in recent years. This has occurred at the same
time as the generation mix has altered, with significant reductions in energy
produced by coal and increases in energy produced by wind and other renewables
and by gas. Thus, the overall impact of changes in the energy generation mix in
favour of renewables and gas has been to reduce the emissions intensity of
electricity generation in Australia, even as absolute emission levels continue
The South Australian Government provided information on the reduction in
emissions brought about by the significant growth in the share of wind power in
its generation mix:
In terms of overall output, wind overtook coal based generation
to become the second most relied upon generation source in the State’s
electricity mix in 2011-12. Data from the National Greenhouse Accounts shows
that emission factors for electricity production in the state has reduced as a
result of wind energy. In 2010 Scope 2 emissions from purchased electricity
produced 0.72 kilograms of carbon dioxide equivalent per kilowatt hour and in
2012 it had reduced to 0.61.
Labor Senators note that claims made by some witnesses that the
interaction between wind farms and other forms of generation in the NEM lead
either to no greenhouse gas abatement or to a massive increase in the
utilisation of coal-fired generation, were comprehensively refuted by material
provided to the committee.
For example, Mr Hamish Cumming claimed that the addition of wind farms
to the electricity grid had resulted in an additional six million tonnes of
coal being burnt at AGL's Loy Yang A plant per year and that wind farms are
forcing the production of more greenhouse gas emissions than would be the case
if they did not exist.
AGL's response to these assertions was as follows:
As demonstrated in AGL's supplementary submission, wind
generation does not materially increase coal consumed at our thermal power
stations. For example...for AGL's Loy Yang A Power Station in Victoria both the
amount of coal combusted and the amount of coal used to generate each unit of
electricity sold has remained reasonably consistent over the past six years -
despite the significant growth of wind power in the National Electricity
Market. This data is consistent with reporting to the Commonwealth Government
under the National Greenhouse and Energy Reporting Act 2007.
Some witnesses argued that the contribution of wind power to the
reduction of greenhouse gas emissions is less than 100 per cent 'efficient' in
that the percentage reduction in greenhouse gas emissions across the whole NEM
is lower than the percentage of electricity generated by wind farms. This
purported effect was attributed to two consequences of the integration of wind
farms into the NEM: first, that wind farms often replace the relatively less
emissions intensive gas generators; second, that when wind farms are operating
coal generators operate under part load, which is less efficient.
The nature of wind farm power generation may lead to some marginal loss
of efficiency of other generators in the NEM. Nevertheless, even on the
calculations provided by those who emphasise this effect, in absolute terms
wind power still leads to significant greenhouse gas abatement calculated
across the whole network.
As noted above, Dr Joseph Wheatley and others maintained that wind power
imposes inefficiencies on other parts of the network such that it does not
reduce emissions at the same rate as it replaces other sources of energy
We looked at the calendar year 2014, and our main findings
were that in 2014 wind power generation provided 4.5 per cent of all energy
generated on the NEM but it reduced emissions by a lesser amount—by 3.5 per
cent. So the effectiveness is the ratio of 3.5 to 4.5, which is about 80 per
cent effective, and we would argue that is a significant loss of effectiveness.
However, regarding the question of how much coal or gas power is
actually displaced by wind power, taking into account any increased standby
requirements on non-renewable generators, the committee received the following
evidence from the Australian Wind Alliance:
The Inquiry has heard evidence that what is required to
properly answer this question is to analyse actual emissions data at short time
intervals from coal-fired power stations. Just such a study was conducted in
2013 by America’s National Renewable Energy Laboratory (NREL) using hourly
emissions data from nearly every power plant in the Western U.S. It was
reviewed by 55 experts including representatives from eight utilities.
This study found that the emissions cost of cycling was
‘negligible’ and that a ‘high wind scenario’ of 25% wind and 8% solar produced
a 29% - 34% decrease in CO2 emissions. That is, 1 kWh of wind (or solar)
generation displaces almost all the emissions from the coal- and gas- fired
power stations that remain in the grid, even when cycling is taken into
The Australian Wind Alliance also highlighted analysis on the situation
in South Australia which suggests that 'wind energy, even at high penetration
levels, does indeed displace the full emissions of the coal and/or gas fired
power it replaces.'
Regarding the high level of wind power in the South Australian generation mix,
Windlab Systems came to the following conclusions:
Wind power generation has increased substantially in South
Australia in the last eight years, from supplying 6% of the state’s needs in
2005/06 to 25% in 2012/13.
This increase in wind generation has been the primary reason
for a 34% reduction in CO2-e emissions due to electricity generation. The
electricity network has managed to accommodate this increase in wind power
without increasing the amount of electricity required from peaking power
Energy produced from these peaking plants has actually
reduced during this same period, which has helped further reduce CO2-e
emissions. Wholesale prices have not risen over the period (even with LGC costs
included) and we conclude the cost of abatement using wind is low.
On the basis of this evidence, it appears that the introduction of
renewable energy abates very nearly all of the emissions generated by the
fossil-fuel generation it replaces.
The related issue of 'spinning reserve' was also raised by some submitters
and witnesses, who argued that, due to its intermittent nature, the
incorporation of renewable energy generation into the electricity grid
increases the requirement to have other generators on standby but not providing
electricity and thereby reduces the efficiency the grid. This issue overlaps
somewhat with the discussion above of the abatement efficiency of wind
The CER provided the following explanation of the purpose of spinning
reserve in the operation of the electricity grid:
Spinning reserve is the generation capacity that is on-line
but not providing electrical energy that can respond to compensate for sudden
generation or transmission outages. Spinning reserves are the first type used
when dispatch shortfalls occur, which helps keep the grid operating in a stable
manner. Because the level of electricity demand varies with time, enough
spinning reserve in the system is required to maintain system stability.
The AEMO is responsible for managing the stability of the NEM. It
provided evidence that directly refuted claims that the introduction of greater
levels of wind has required an increase in capacity dedicated to maintaining
the stability of the grid.
The AEMO noted that it does not employ the term 'spinning reserve',
which originates in North America, and that the NEM, due to its design, does
not have a directly comparable feature. The AEMO does, however, operate a
Frequency Control Ancillary Services (FCAS) market, which it explained as
AEMO operates “Frequency Control Ancillary Services” (FCAS)
markets which match supply and demand over timescales shorter than the NEM’s
energy dispatch cycle of five minutes. Beyond that timescale variations are
balanced by energy dispatch. In some overseas markets the dispatch cycle is longer,
e.g. 60 minutes, requiring balancing services beyond the scope of FCAS. Some
energy markets operate on a day ahead basis rather than in real time.
The AEMO further explained that it has not changed the amount of FCAS in
response to the rising level of wind generation in the grid and that FCAS costs
represent only about one per cent of market turnover:
AEMO recruits sufficient FCAS in order to meet the frequency
standards and keep the power system secure at all times. To date AEMO has not
measurably changed the amount of FCAS it recruits as a result of the growth in
wind generation. It is possible that more of one form of FCAS – regulation –
may be required in time due to the sub five-minute variability of wind
generation. It should be noted that total NEM FCAS costs are relatively small,
comprising about one percent of energy market turnover.
The AEMO emphasised that, although renewable generation does present
some technical challenges, the NEM is uniquely well placed to deal with them
due to its design. It again emphasised that it has not increased ancillary
services in response to increasing levels of renewable generation:
The NEM has been uniquely successful in securely integrating
wind generation to date at low cost. For example, AEMO has not had to change or
materially increase the quantity of ancillary services purchased to maintain
It is important to note that spinning reserves are maintained in order
to meet 'sudden generation or transmission outages'. The committee received
evidence that, although wind generation is certainly intermittent in that it
generates electricity only when the wind is blowing, it is also generally
highly predictable. Pacific Hydro referred the committee to the Australian Wind
Energy Forecasting System operated by the AEMO, which enables the efficient
operation the electricity dispatch system by accurately forecasting wind
conditions across the country.
It is also important to note that spinning reserves are a feature of the
operation of the electricity grid regardless of the presence of wind generation
and that the size of the spinning reserves, or contingency, are generally
determined by the largest power station in the grid so that its sudden loss
would not unbalance the system. This matter was explained by RATCH-Australia
In terms of the size of the reserve that needs to be sitting
there waiting as backup, our national electricity market, called the NEM,
considers that a credible contingency event is the unexpected loss suddenly of
one power station on the network. So the spinning reserve backup needs to be
large enough to cover the loss of electricity generation in case any one of the
currently operated power stations suddenly shuts down.
I am simplifying a little here because the details get very
technical, but the critical case here is if the largest of the currently
operating power stations suddenly shuts down, so the spinning reserve is sized
to cover this one, the largest one. If it is going to cover the loss of the
largest power station then it would cover the loss of any of the others if they
were to fail as well. Up to this date in the NEM, the largest power station has
been a coal fired power station. Wind farms can be quite big, they can comprise
many turbines, but overall the size of a wind farm is generally a fair bit
smaller than the size of one coal fired power station. So the spinning reserve
is sized to cover the loss of one coal fired power station.
So there is no extra requirement for spinning reserve due to
wind turbines. If a wind turbine was to fail, if a whole wind farm were to
fail, if the wind suddenly stopped blowing, which is something that does not
actually happen—the wind is very predictable and forecastable, and it does not
just stop blowing—but let's say for some reason a wind farm suddenly shuts
down, whatever backup is there would be there, whether or not that wind farm
was operating, because there is always a larger power station which it needs to
be there for as well.
Using the example of South Australia, Pacific Hydro also explained that,
despite the very high level of wind power in that state, there had been a
decrease in the capacity of coal-fired power stations:
South Australia has significantly more wind energy than any
other Australian state, which makes it a good case study when it comes to
integrating wind energy into the grid. According to the Australian Energy
Market Operator, wind generation in South Australia was sufficient to meet the
state’s entire operational consumption for the first time on 27 June 2014
between 4.10 am and 4.35 am. AEMO have also found that for 90% of the time,
South Australian wind generation varies by less than 2% across five-minute
periods, and by around 3% across 10-minute periods. In addition to this, AEMO
reports that the capacity factor of coal stations is dropping in the state,
clearly demonstrating that wind farms are displacing coal fired power
generation in the state.
Labor Senators therefore conclude that the issue of maintaining
sufficient 'spinning reserve' is one that affects the electricity network as a
whole, rather than renewable generation in particular. No type of power
generation is completely reliable and capacity must be maintained to cover
unexpected events; this is a consequence of maintaining a reliable grid and
cannot be attributed only to the presence of renewable energy generation.
Labor Senators highlight the summary of this matter provided by the CER:
As spinning reserve is required to maintain system stability,
one MWh of renewable generation may indeed not displace the exact amount of
fossil-fuel generation required for the same one MWh of electricity. On the
other hand, it should not be assumed that fossil-fuel generators continue to
burn fuel and hence generate emissions at the same rate regardless of the
amount of renewable generation (mostly wind) that is dispatched. Overall, it is
more likely that the extra emissions from increased spinning reserve are a
small proportion of the emissions reductions from displacement of fossil-fuel
Labor Senators also emphasise that assertions made by some witnesses
that renewable energy certificates are being incorrectly claimed because the
actual greenhouse gas emissions achieved by the introduction of renewable
generation varies depending on which form of generation is displaced at a given
point in time are also baseless. Such a claim was put to the committee by
representatives of the Association for Research of Renewable Energy Australia.
Further criticisms of the conduct of the CER founded on this claim are also
First, as noted by the CER, clean energy certificates are not granted on
the basis of greenhouse gas abatement, but on the basis of electricity
generated. The CER emphasised this point and explained:
The eligibility formula makes no reference to the amount or
emissions intensity of fossil-fuel generated electricity that is displaced by
the renewable generated electricity. Therefore, the Regulator is neither
required, nor has the power, to vary the number of LGCs issued according to
emissions reductions achieved.
As a matter of practicality this would be exceedingly
difficult to determine on a case by case basis because of the pooled nature of
the electricity market. Generators offer to supply the electricity market with
specific amounts of electricity at particular prices. Dispatch prices are
determined every five minutes (aggregated to a 30 minute trading interval) and
it would be difficult to establish what would have been dispatched in the
absence of the renewable electricity and hence what emissions were avoided at
Second, as presented in the discussion above of Dr Joseph Wheatley's
claims, strong evidence was provided to the committee that in fact renewable
generation does displace very nearly all of the emissions from fossil fuel
The claims presented to the committee regarding the invalidity of
renewable energy certificates is mistaken about both the legal foundation on
which the certificates are issued and the factual question concerning the level
of abatement achieved by renewable generation.
Based on the evidence presented to the committee on element (h) of the
terms of reference, Labor Senators believe that there is a great deal of
information available on the greenhouse gas emissions intensity of wind power
and on its overall effect on the emissions intensity of the NEM. On both
measures wind power is clearly having a positive impact and its further
development should be encouraged.
Senator Anne Urquhart Senator
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