A follow up letter sent to WorkSafe Victoria, including a Blade Throw Risk Assessment undertaken at Hills of Gold Wind Farm in NSW.
The supplementary letter includes the following:
- Alerting WorkSafe to the risk of human life due to blade throw and blade fragment throw,
- Calling on the requirement of all Wind Farms in the Moyne Shire to be re-designed in order mitigate against the risk to the public from blade throw or blade fragment throw events,
- Alerting WorkSafe to their duty of care for the safety of the public and also their duty to alert and protect employers and duty holders from the risk of criminal manslaughter.
Watch out for flying blade fragments
Wind Farm Living, Moyne Shire
27 January 2021
WorkSafe Senior Inspector
1 Malop St.
Geelong, VIC 3220
Attention: WorkSafe Victoria Senior Inspector,
RE: Case Number ID: ID-68215: AGL operations – Macarthur Wind Farm.
I wish to provide further evidence to support my complaint against AGL’s operations at the Macarthur Wind Farm (Case ID: 68215).
Studies have shown that there is a risk to human life associate with “blade throw and blade fragment throw” from wind energy generating turbines and I wish to draw your attention to the Blade Throw Risk Assessment undertaken as part of the Environmental Impact Statement of Hills of Gold Wind Farm in NSW. (Appendix K “Blade Throw Risk Assessment” – see attached)
The Hills of Gold Wind Farm Blade Throw Risk Assessment makes the following conclusions:
- The likelihood of maximum throw distance for entire blades and blade fragments is 150 metres and 500 metres respectively.
- Studies show that the maximum blade fragment throw distance is between about 500-800 metres under normal conditions.
- The risk assessment concludes that in the event of a blade throw event, the consequences could be significant with damage to human life and property.
Although the Blade Throw Risk Assessment assumes the risks associated with a blade throw event is low for the Hills of Gold Wind Farm, the risk to human life exists and should be considered.
Victorian OH&S Laws, section 98 (1) of the OH&S Regulations Act 2017, requires that so far as is reasonably practicable, risk controls are to be implemented to eliminate any risk associated with plant. AGL, is therefore required by law, to mitigate against all risks associated with the wind power plants including blade throw and blade fragment throw.
To eliminate risk to the public, it is reasonably practical for AGL to isolate the wind energy generating plant using the following risk mitigation controls:
- Establish a one kilometre “No-Go Zone” radius around the turbine, to minimise injury or death due to catastrophic blade failure.
- Install security fencing around the perimeter of the “No-Go Zone”.
- Install a locked security gate and a formalised management system for access and egress to the “No-Go Zone”.
- Use engineering controls to turn the spinning blades off when a person enters the “No-Go Zone”.
- Decommission and remove any turbine if the 1-km “No-Go Zone” cannot be established on the Host Owner’s land.
The Blade Throw Risk Assessment made note that there is little public information available about blade throw events and that the following have been reported:
- Bald Hills Wind Farm, VIC (2020)
- Lal Lal Wind Farm, VIC (2019)
- Wonthaggi Wind Farm, VIC (2012), and
- Windy Hill Wind Farm, QLD (2005).
I understand that WorkSafe has also investigated the blade throw event at Dundonnell Wind Farm, in October 2020.
I have inserted photographs of the Bald Hills, Lal Lal and Dundonnell blade throw events for your information.
As a concerned member of the public, I ask that WorkSafe Victoria ensure that AGL complies with all relevant OH&S Laws and Regulations applicable to the power plant energy generating industry, and that the actions undertaken by WorkSafe are not influenced in any way by the size and public profile of the company, or by any Government department such as the Wind Farm Commissioner’s and/or the Victoria Planning Minister’s department.
I also ask that, unless Wind Farm Developments are above the law, WorkSafe Victoria intervene in the construction of all Wind Farms in Moyne Shire, whether permitted or not, until all blade throw and blade fragment throw risks are assessed. I also request that these Wind Farms are modified according to the risk mitigation controls listed above to ensure that workers and the public are not exposed to risks associated with a blade throw or blade fragment throw event.
The fact that no wind farm fatality has occurred to date is no reason not to apply the full force of the OH&S laws to wind farm operations. The likelihood of a fatality occurring will only increase as the many hundreds of turbines are installed throughout the densely populated rural communities of the Moyne Shire. Allowing Wind Farms to operate outside the law, exposes the company owners, their duty holders, and all other associated officers, including Moyne Shire officers to the new criminal offence charge of manslaughter (see attached). It is therefore incumbent of WorkSafe Victoria to not only protect the employees and public from the risks associated with the high-risk plant operations, but also the owners, officers, and duty holders from exposure to criminal litigation due to negligence.
I note this letter is to be included as additional supportive evidence to my existing Case No. ID-68215, and that this letter will be distributed to all and sundry as a record of my notification of complaint.
Cc Andrew Dyer, Federal Wind Farm Commissioner.
Cc Richard Wynne, Minister for Planning.
Cc John Bradley, Secretary of DELWP
Cc Moyne Shire, Responsible Authority
Cc CFMEU, Mr J Simpson
Cc Wind Farm Living Community, Moyne Shire
|Bald Hills Wind Farm – blade throw||Bald Hills Wind Farm – turbine dangerously close to neighbour’s adjoining land, presenting a risk to farmers and their employees.|
|Lal Lal Wind Farm – blade throw||Dundonnell Wind Farm – blade throw|
A split blade at Cape Bridgewater windfarm in 2013 posed a likely risk to the public.
DeFrock understands it took months for the blade to be taken down, removed offsite and replaced.