Wind Turbines
- An Accident Waiting to Happen?
The danger to the
public from wind turbines is clearly illustrated
by the growing number of accidents worldwide involving
giant turbines catching fire, shedding blades
or parts of blades and throwing large ice lumps.
Industrial sized on-shore wind turbines with large
rotating blades pose an element of danger to both
the public and property in the surrounding area.
The fact that these blades rotate at a great height
above the ground means that any failure or partial
failure of a blade or falling ice can be projected
some distance and over a wide area.
This danger
is increased when turbines are sited in close
proximity to high voltage electricity lines, homes
and a busy road running in an East to West direction,
as in the recent Seamer planning applications.
Two recent events in the UK highlight
this growing problem:
Whittlesey, Lincs, December 2008:
Huge lumps of ice were thrown onto homes and gardens
from the blades of a giant wind turbine. Freezing
overnight temperatures had caused the ice to form:
the turbine did not turn off automatically when
the ice started to shed. People had to take cover
as lumps of ice - some two feet long - showered
them from the 80 metre high turbine tower. The
Health and Safety Executive is now investigating
the incident, and the local MP is calling for
a public inquiry.
Manchester, December 2008: Wind
energy developer Ecoctricity withdrew plans to
erect a wind turbine at Manchester City stadium
because of a "one in a million" chance of ice
throw. They stated "We don't feel that we can
accept even this small level of risk. We don't
feel the risk to the public, to the reputation
of the club, to Ecotricity and to wind energy,
is worth taking". Various methods of combating
the problem were considered, but the project was
abandoned.
Present Situation
The lack of
a regulating body to set, monitor and enforce
health and safety standards for the wind industry
has resulted in confusion and division of responsibility
between the various central and local government
bodies. With no over-all body in charge, none
of the parties involved accepts responsibility
for evaluating the dangers and carrying out a
Risk Assessment.
The planning process for commercial
wind turbine installations DOES NOT REQUIRE OR
INCLUDE AN ASSESSMENT OF THE RISK WIND TURBINES
POSE TO THE PUBLIC AND PROPERTY.
Those involved
in processing the developer's planning application
include the local Planning Authority, Statutory
Consultees and local Councillors on the Planning
Committee.
Yet, in the case of the Seamer application,
it appears that only the local councillors on
the Planning Committees were prepared to acknowledge
the risks involved.
The Developers
In submitting a proposal, wind energy developers
are required to comply with Planning Policy Statement
22: Renewable Energy (PPS22). Guidelines are also
given in "Planning for Renewable Energy A Companion
Guide to PPS22". Both the Policy Statement and
the Guidelines were issued in 2004 and have not
been updated since then. Relevant paragraphs of
this document are listed in Appendix 1.
It is notable that instrumental in the production
of the Companion Guide (Technical Annex: Wind)
is the British Wind Energy Association, the Trade
Body which looks after the interests of wind energy
developers.
PPS22 recognises the "danger to human
or animal life" by loss of turbine blade or partial
blade and fragments of ice released from the blades,
but does not advise how to quantify such danger
or how to mitigate against the danger.
PPS22 also
recognises the "Shadow Flicker and Reflected Light"
effect from a wind turbine but limits this effect
to "occur inside buildings". It does not consider
this effect on users of nearby roads.
Although
it acknowledges the risks from wind turbines,
PPS22 does not require wind energy developers
to carry out a Risk Assessment. This is effectively
a loophole for developers, who are well aware
of the risks posed by wind turbines.
Developers
use this loophole when responding to queries regarding
Risk, merely pointing out that they have complied
with PPS22. However, PPS22 is outdated, does not
adequately describe the risks associated with
modern industrial wind turbines, and is widely
criticised by many eminent and professional people.
FACT: DEVELOPERS
DO NOT ASSESS THE RISKS TO THE PUBLIC
Local Planning Authorities
Local
Planning Authorities are driven by the Government's
targets for Renewable Energy installations and
keen to avoid any penalties imposed by Government
for failing to meet the targets imposed upon them.
Local Planning Authorities apply PPS22 guidelines
to determine wind energy planning applications.
They also engage with Statutory Consultees, including
those with a responsibility for safety, namely
Highways Agency, Local Highways Authority and
National Grid. However, Planning Authorities do
not involve themselves in Risk or Health and Safety
issues with regard to wind turbine applications.
In a presentation to BWEA in October 2008, Nick
Summers of the Health and Safety Executive stated:
"When developer seeks planning permission for
a wind farm, potential risks to public safety
should be assessed within the planning framework
process"
"Some risks to public are best addressed
through planning controls as well as H&S legislation"
"Promotion of clear guidelines and their application
by planning authorities to deal with risks to
the public, relevant standards and industry good
practice, should minimise risks to the public"
Clearly, the Health and Safety Executive believe
that Risk Assessment should be within the remit
of Local Planning Authorities. Local Authorities
should therefore incorporate this requirement
in their Local Development Framework Policies
covering wind turbine installations
FACT: LOCAL PLANNING
AUTHORITIES DO NOT ASSESS THE RISKS TO THE PUBLIC
Highways Agency
The current policy being used by Highways Agency
is Network Strategy - Spatial Planning Advice
Note: SP 04/07 - Planning Application for Wind
Turbines Sited Near to Trunk Roads. However
this policy only applies to Motorways and Trunk
Roads and is not applied to the majority of
planning applications for wind turbines.
This policy was issued as a Working Draft in
December 2006, and issued in March 2007. It
was updated in July 2007 and is still in use.
Relevant paragraphs of this document are listed
in Appendix1.
This policy recognises the need to locate wind
turbines further away from Trunk Roads than
the distance recommended in PPS22. The HA recommendation
is turbine height plus 50 metres.
With regards to "Shadowing" or "Flicker" it
recommends: "..., a separate, site-specific
assessment of risk may be prudent."
When questions of safety or risk are raised
with the Planning Authority, they pass these
on to the developer. The developer's response
is, invariably, not to answer such questions,
but to merely state that the planning application
complies with PPS22.
The developer is responsible for hazards and
risks associated with wind turbines. However,
the wind industry is self-regulated and if the
developer states that he has complied with PPS22,
this is accepted by the Highways Agency and
the Local Planning Authority.
The identified safety problems or risks
associated with Trunk Roads and road users are
then not quantified or mitigated against.
FACT: THE HIGHWAYS
AGENCY DOES NOT ASSESS THE RISKS TO THE PUBLIC
Local Highways/Transport Authority
The Local Highways/Transport Authorities do
not have policies with regards to wind turbines
and rely on their own initiatives when responding
to planning applications which affect their
road networks.
It would seem sensible to utilise the Highways
Agency Standard SP 04/07 listed above but Local
Transport Authorities choose not to do so. Accordingly
road users using other than Motorways and Trunk
Roads are exposed to a greater level of risk
from wind turbines. This is surely illogical,
and does not adequately protect the general
public.
Again, if questions of safety or risk are raised
with the Planning Authority, they contact the
developer, who in turn assures them that the
planning application complies with PPS22. If
the developer states that he has complied with
PPS22, this is accepted by the Local Highways/
Transport Authority and the Local Planning Authority.
Once again the identified safety problems
or risks associated with roads and road users
are then not quantified or mitigated against.
FACT: THE LOCAL
HIGHWAYS/TRANSPORT AUTHORITY DOES NOT ASSESS
THE RISKS TO THE PUBLIC
National Grid
The guideline currently used by developers is
National Grid (Energy Network Association) Technical
Specification 43-8 for "Overhead Line Clearances",
Issue 3 (2004) for safe separation to power
lines. This indicates fall over distance plus
4 metres BUT acknowledge that this does not
apply to wind turbines.
However National Grid - Internal and Contract
Specific Policy Statement (Transmission) issued
a new policy entitled "Overhead Line Separation
from Wind Turbines PS (T) 087 - Issue 1 - September
2008"
Part 1.2 Existing Overhead Lines states:
"The requirements of 2002 Electricity Safety,
Quality and Continuity Regulations shall be
met in regard to both the nature of the equipment
and the surrounding land use. All possible measures
must be made to safeguard existing OHL assets
by seeking to ensure new wind turbines are constructed
at a distance more than 5 times the rotor diameter
away from any OHL."
To date, National Grid has not applied
this policy: they are awaiting supporting data
(expected in the first quarter of 2009). Once
finalised, it is expected
they will apply this policy to all new wind
turbine applications.
FACT: THE NATIONAL
GRID DOES NOT ASSESS THE RISKS TO THE PUBLIC
Health and Safety Executive
The Health and Safety Executive plays no roll
in the planning process for wind turbines in
spite of being the Statutory Body which issues
all the policies with regards to safety and
risk associated with protecting people in the
workplace.
HSE starts from the position that: "A suitable
and sufficient Risk Assessment must be undertaken
to determine the measures needed to ensure that
risks from the hazard are adequately controlled."
HSE Policy: Reducing Risk Protecting People
- R2P2 would be an appropriate document to evaluate
such risks from wind turbines.
However, HSE policies only come into effect
once the construction of the wind turbines commences,
and they cover employees on the site rather
than the general public in the vicinity of the
site.
FACT: THE HEALTH
AND SAFETY EXECUTIVE DOES NOT ASSESS THE RISKS
TO THE PUBLIC
Summary
WHO IS LOOKING AFTER PUBLIC SAFETY?
- NO ONE!!!
Neither the Developers,
the Local Planning Authorities, the Highways
Agency, the Local Highways Authority, the National
Grid nor the Health and Safety Executive assess
the risks to the public
APPENDIX 1 - PPS22
PLANNING POLICY STATEMENT 22: RENEWABLE ENERGY
(PPS22) AND PLANNING FOR RENEWABLE ENERGY A
COMPANION GUIDE TO PPS 22
Section 8 - Wind covers Safety in paragraphs
49 to51.
Paragraph 50 states:
"The only source of possible danger to human
or animal life from a wind turbine would be
the loss of a piece of the blade or, in most
exceptional circumstances, of the whole blade."
NB: There is evidence
available that clearly shows the above statement
to be untrue as there have been numerous instances
of thrown ice, collapsing towers and the frequency
of loss of blades, partial or full, is also
increasing at an alarming rate.
Paragraph 51 states:
"The minimum desirable distance between
wind turbines and occupied buildings..... Fall
over distance (i.e. the height of the turbine
to the tip of the blade) plus 10% is often used
as a safe separation distance."
NB: PPS22 does not provide
guidance on risk assessment of the effect of
blades rotating at tip speeds of up to 180 mph
and the projected range of debris from loss
of a piece of blade or thrown ice.
Section 8 - Wind also refers to safety
in Proximity to Roads, Railways and public Rights
of Way and Power Lines in paragraphs 52 to 57.
Paragraph 53 states:
Although a wind turbine erected in accordance
with best engineering practice should be a stable
structure, it may be advisable to achieve a
set-back from roads and railways of at least
fall over distance, so as to achieve maximum
safety."
Paragraph 55 states:
"Wind turbines should be separated from overhead
power lines bin accordance with Electricity
Council Standard 44-8 'Overhead Line Clearances'."
NB: Electricity Council
Standard 44-8 is now replaced with National
Grid (Energy Network Association) Technical
Specification 43.8 but National Grid have confirmed
that this specification takes no account of
the impact of wind turbines on overhead lines.
Section 8 - Wind covers Shadow Flicker
and Reflected Light in paragraphs 73 to 78.
Paragraph 73 states:
"...It only occurs inside buildings where
the flicker appears through a narrow window
opening...."
NB: PPS22 makes no reference to the effect "flicker
or reflected light" would have on road users.
Paragraph 76 states:
"...Flicker effects have been proven to
occur only within ten rotor diameters of a wind
turbine...."
NB Yet PPS 22 allows wind
turbines to be site at only height plus 10%
from roads and railways.
Section 8 - Wind covers Icing in paragraph
79.
Paragraph 79 states:
"...In those areas where icing of blades
occur, fragments of ice might be released from
the blades when the machine is started...."
NB PPS22 again identifies
the risk but not how to address it or quantify
the level of risk.
NB PPS22 was produced in 2004 and has not been
updated since then.
APPENDIX 2 - HIGHWAYS AGENCY
NETWORK STRATEGY - SPATIAL PLANNING ADVICE NOTE:
SP 04/07 -
PLANNING APPLICATIONS FOR WIND TURBINES
SITED NEAR TO TRUNK ROAD
Structural Collapse is covered in paragraphs
7 and 8.
Paragraph 7 quotes PPS22 and states:
"..., it may be advisable to achieve a set-back
from roads and railways of at least fall distance
(height measured to blade tip) to achieve maximum
safety."
Paragraph 8 states:
"However, given the potential consequences were
debris to fall on a busy motorway or trunk road,
an additional allowance for debris scatter is
necessary in order to truly maximise safety."
Icing is covered in paragraphs 9 to 11.
Paragraph 10 states:
"Warming or fragmentation may then lead
to ice being shed from the rotating blades.
Large fragments may be thrown a considerable
distance."
Paragraph 11 states:
"...Nevertheless, the consequences of an
ice projectile hitting a moving vehicle could
be severe. Not only would the occupants be at
risk but a multi-vehicle accident could result."
Location is covered in paragraphs 12
and 13.
Paragraph 12 states:
"Consideration of the risks associated with
structural failure and 'icing' identifies the
clear need to incorporate a safety margin in
the offset between the trunk road boundary and
the siting of a wind turbine......Commercial
turbines should be se back a distance equal
to height + 50 metres."
'Shadowing' or 'Flicker' is covered
in paragraph 21.
This states:
"A final source of potential distraction
is moving shadows across the carriageway by
rotating blades. This should be ameliorated
considerably by the suggested offset.
However, a separate, site-specific assessment
of risk may be prudent."
Wind Turbulence is covered in paragraphs
22 and 23.
Paragraph 22 states:
"...The distance over which the turbulence
of a turbine can be felt (its wake) can be up
to three times the rotor diameter in distance.
Therefore, care should be taken when locating
turbines at sites where non-motorised road users
are likely to be passing.
Paragraph 23 states:
In such circumstances, a site specific assessment
should be undertaken and, if necessary, effective
screening should be provided to shield non-motorised
users from the generated air turbulence."
NB This policy was issued
a Working Draft in December 2006, and issued
in March 2007. It was updated in July 2007 and
is still in use.
Working Note: Purpose of this document
1. To Highlight the fact that no Risk
Assessment is done/required by Local Authority,
Highways Authority etc.; that the wind industry
is self-regulated and has no over-arching Regulatory
Body (covering letters to be created for Local
MP's, MEP's, Cllrs, Planning Authority)
2. To
raise awareness of these issues by seeking national
and local press coverage (covering letters to
be created for DT (Christopher Booker), DEx,
NEcho, D&S T, Evg.Gaz..) |
