27 Nov 2012
Airport and Aviation Protection Group - providing governance oversight
The Airport and Aviation Protection Group inception was circa 2008 when we met to defend Crookwell Aerodrome from the incursion
of the Gullen Range Windfarm, as proposed by the Epuron development application. Where we appeared in the NSW Land and Envirnoment court
and successfully contested the removal of 11 wind turbines; we did so with our own efforts, and own private funding, in our own time, and were
the only group to actually set the legal precedent - of which we are proud.
The history may be read at Wind Turbines.
The group has actively been involved in lobbying government, and during this period to date, we have received more than our fair share of resistance.
It turns out that all our earlier efforts, other than the removal of 11 turbines,
have been undone due to commercial and political influence:
Unfortunately no-one is addressing our original concerns for unregistered and uncertified aerodromes,
and no one organisation has given any consideration to Wind Turbine Wake Plumes.
There was hope that Australia was to be the first Aviation State to address our concerns, and we felt that hope when we received the promise of
legislation, but instead we find several years later
that they are not even following ICAO recommendations for wind turbine markings and lighting; so we have no recourse but to lobby the senate to point
out these glaring deficiencies in oversight and governance.
Mid November 2012 we have learned that CASA is concerned but is unable to act due to political influence, as well as due to the usual excuse of lack of legislation.
The Airport and Aviation Protection Group released
their initial policy statement to the Senate on 29 Nov 2012 regarding the
hazards that wind farm turbines represent to aviation.
Wind Turbine Wake Plumes are a Hazard to Aviation
Wake Plumes visible by condensation at Horns Rev wind farm Denmark - note the extent.
Whereas government has been concentrating on the physical obstruction aspects, the group has been concentrating on the turbine wake fields, which we have termed
Wake Plumes, to emphasise that they are comprised of a vortex wake field in combination with a velocity deficit that is contained and does not significantly
diverge as it flows downstream. (Equations and references are available on request to demonstrate their extents.)
You can clearly see several very important aspects of these Wake Plumes within the Horns Rev photograph:
- that they do not diverge significantly, and
- that they interact when aligned, and
- that they travel downwind for significant distances.
It turns out that the Wake Plume contains a velocity deficit, where the aiflow within them is significantly slower than the free stream velocity,
which means the plume is a wind-shear to aicraft, and the turbulence within the Wake extends further than the velocity decifit.
In the case of the Horns Rev wind farm the deficits have been measured in excess of 20 kms downstream, so the Wake Plume effect is very significant.
We also have a Windmills in the Mist video of these Wake Plumes as they disperse fog surronding the Cullerin Range windfarm.
This video shows just how dangerous grey and hidden blades are when they protrude from cloud. (This video is best viewed by saving to file and then opening with the Quicktime video player.)
Duty of Care
Under the section 266 of the Criminal Code - "it is the duty of ... everyone who has in their charge or under his control anything,
whether living or inanimate, or who erects makes or maintains anything whatever, who in the absence of precaution or care may endanger human life,
is under a legal duty to take responsible precautions against and use reasonable care to avoid such danger, and is criminally responsible for the consequences of omitting
without lawful excuse to perform such duty".
R v Pacino: Extending the criminal Negligence Ian McFarlane (accessed 11 December 2007).
This in particular covers anyone, including the proponent, the land owner, the government, government employees, and their ministers, who as the controlling and approving authorites are exposed to negligence should incidents arise. The law is even clearer, they are
to take reasonable care to avoid such incidents before the fact; Affordable Safety just does not bode well with the common law. This ruling in fact should empower any
government body that
to date believes they have been unable to act under the law, and enable them to take precautions to address the safety of life before they are deemed negligent.
Wind Turbine Policy
Wind turbines represent obstructions and physical hazards due to their sizes, aerodynamic nature, and the extend of their Wake Plumes. The towers, blade disks,
infrastructure such as metrological observation towers, and the excessive turbulence and the velocity deficits that occur downstream in the Wake Plume being a void to flight, representing
severe wind-shear and turbulence that has been found to disrupt aircraft control, are all very dangerous hazards in themselves. Couple this with the political emphasis for green power,
carbon offsets, electricity credits, and other tax incentives, we now see a large proliferation of
wind farm development; based on a new technology that has been outpacing the science and planning authorities alike, who have so far shown an utter disregard of the aviation safety aspects;
exacerbating the danger to aviation in any given area.
Our policy towards wind farm placements near aviation infrastructure follows:
Proponents are to:
- light structures that at taller than 360' above ground (109.7m) a figure that is employed for pilot calculated Lower Safe Altitude, and
- mount orange balls on any tower guide-wires, and paint the top section of a tower in contrasting colors, e.g red and white, and
- paint turbine blades tips with contrasting colours, e.g. orange tips or orange and grey stripes, so they can been seen projecting from cloud, and
- Provide setback allowance of turbines from commercial, general, agricultural, and sports aviation; including sail boating infrastructure and activities,
aerodromes, airports, airstrips, landing
and circling areas, float-plane, sail-plane, gliding, and known: parachuting, hang-gliding, kite soaring and para gliding areas; this is to include siting
away from beaches so offshore wind does not cause the wake plume to encroach on the beach nor over ocean sailing vessels, and water landing areas;
and away from recreational dams, where any reasonable person expects that may be sail
boat activity currently or within the future. (E.g. away from harbours, popular beaches, and known areas of hang-gliding, sail-boarding, sail-kiting, gliding, parachuting,
as well as any landing area, registered or not, where landing area may also include the ocean for float-plane activity, and also areas where sail boats may operate.)
- In determining the setback allowance it is to conform to legislation and advisories from CASA and Department of Infrastructue and Transport, and any other enacted legislation from other authorities,
and to take into account the extent of the wake plume and provide sufficient buffer between the wake plumes and the area of concern. Turbine wake plumes must neither
be allowed to touch nor cross operational areas, such as let-down and circling areas - must be a sufficient buffer-zone as well as the set-back distances.
This setback shall be taken to be 50 times the blade diameter from the nearest turbine, until a different legislated distance is otherwise determined.
- perform wind turbine wake plume analysis for their selected turbines using the environmental parameters including turbine placement, surface roughness
and environmental contribution of roughness, with statistically significant wind analysis, including prevailing and adverse winds for the area of placement, and present those findings
for review as part of the development application. (Where adverse wind means the worst case wind for a particular infrastructure that may be affected.) In the case of aviation
including soaring sites, the information shall be forwarded for approval and comment by: CASA, Gliding Federation of Australia, RAAus and Hang Glider Federation of Australia; in the case for agricultural and fire-fighting operations the Aerial Agricultural Association of Australia and
the fire-fighting authorities of each state;
as part of the Development Application review process.
The things that the aviation industry need done immediately:
- legislate a setback distance of 50 times the blade diameter, and
- legislate contrasting blade-tip markings (orange or red blade-tips whith/without stripes), and
- legislate aviation hazard lighting for structure heights above 360' (can consider transponder actuated as the Wollongong towers operate so lighting doesn't need to be on all night), and
- legislate the marking of tower guide-wires with orange balls, and
- alter paragraph 20 of the Guidelines D to cover all aerodromes and airstrips, irrespective of registration status, because the registration status of an airstrip
is irrelevant in terms of the hazard, and
- alter paragraph 31 of the Guidelines D to wind turbines over 360', irrespective of whether they penetrate the OLS; the OLS is insufficient, and
- re-open the CASA wind turbine and obstruction project, and
- commission a scientific study to determine a safe distance which is to be based on turbine parameters, such as: blade-disk diameter, turbine thrust coefficient, and
the extend of turbulence and velocity deficit generation within the wake plume, and to include
actual measurements, e.g. perform measurements via LIDAR, not just theoretical; with the view to draft legislation. Such a study would also be required to include effects on
agricultural and other low-level operations such as: spraying, fire-fighting, power-line and gas-pipeline surveying, because siting
wind-turbines with their obstruction and wake plumes in the way runs the danger of making these operations impossible, and
- impose a moratorium or injunction on development and development approvals, until the proponent has performed an appropriate aviation risk assessment treating
the wake plumes, or demonstrates conformance with the intent of the above legislation.
The subsequent things that need to be done:
- CASA to conduct a review of all CASA approved consultants and their companies, in particular to review the level and standard of all Aviation Hazard Assessment reports that have
been submitted in regard to wind farms to date, and
- Enact the findings of the CASA study into law and absorb or strengthen Guidelines D. Since different State authorities are involved federal guidance is required,
these findings should be enacted as instruments of law to ensure national conformity, and to make the way clear for all developers with no ambiguity, and
- Initiate a safety education program to inform industry, and
- Survey existing wind farm developments to determine how much, if any they have encroached on infrastructure, and determine actions should aviation infrastructure use be damaged.