General duties of wind farm owners and operators

Purpose

This guidance note highlights the general duties of wind farm owners and operators for:

• ensuring the safety of any person and property;
• bushfire risk mitigation; and
• reporting incidents to Energy Safe Victoria.

It also gives information to support wind farm owners and operators to understand their general duties and Energy Safe’s expectations, particularly relating to safety controls and fire risk mitigation.

General duties of wind farm owners and operators

Wind farms are typically complex electrical installations, being electrical installations that have an installed generation capacity of equal to or greater than 1000 kVA.

Under section 75(1) of the Electricity Safety Act 1998 (Vic) (Act), owners and operators of complex electrical installations have general duties to minimise the hazards and risks and bushfire danger arising from the installation, as far as practicable.

General duties of wind farm owners and operators

An owner or operator of a complex electrical installation must design, construct, operate, maintain and decommission the installation to minimise as far as practicable—

• the hazards and risks to the safety of any person arising from the installation; and
• the hazards and risks of damage to the property of any person arising from the installation; and
• the bushfire danger arising from the installation.

The penalties for non-compliance with the general duties are:

• In the case of a natural person, 1800 penalty units (currently $355,662); and
• In the case of a body corporate, 9000 penalty units (currently $1,778,310).¹

Under regulations 401 and 402 of the Electricity Safety (General) Regulations 2019 (Regulations), operators of complex electrical installations also have obligations to report serious electrical incidents and other electrical incidents to Energy Safe.

¹From 1 July 2024 to 30 June 2025, the value of a penalty unit is $197.59. The value of a penalty unit is raised on 1 July each year in line with inflation.

Incident reporting obligations of wind farm owners and operators

Serious electrical incidents:

• An operator of a complex electrical installation who becomes aware of any serious electrical incident occurring within that complex electrical installation must report the incident to Energy Safe as soon as practicable after becoming aware of the incident.

Other electrical incidents:

• An operator of a complex electrical installation who becomes aware of any of the following incidents occurring within that complex electrical installation must report the incident to Energy Safe within 20 business days after becoming aware of the incident.
  • An incident involving electricity in which a person has made accidental contact with any electrical installation; or
  • An incident involving electricity in which a person has received an electric shock as the result of direct or indirect contact with any electrical installation.

For the purposes of the Regulations, a serious electrical incident is defined under the Act as any incident involving electricity that causes or has the potential to cause:

• the death of or injury to a person; or
• significant damage to property; or
• a serious risk to public safety.

Energy Safe considers that any incident involving fire originating from any part of the electrical installation or equipment, including a wind turbine blade, is a serious electrical incident and must be reported. Fire includes any event with evidence of charring, smouldering or melting.

Further information about reporting incidents to Energy Safe is available here.

Understanding your general duties

As an owner or operator of a wind farm, you must identify all foreseeable hazards and risks arising from your complex electrical installation, identify the controls available to eliminate or reduce the risks and:

• implement the most effective control or combination of controls to eliminate each risk where that is practicable, or
• where it is not practicable to eliminate a risk, implement all practicable controls that contribute to the minimisation of the risk.

What is ‘practicable’ must be determined having regard to the following factors:

• the severity of the hazard or risk in question; and
• the state of knowledge about the hazard or risk and any ways of removing or mitigating the hazard or risk; and
• the availability and suitability of ways to remove or mitigate the hazard or risk; and
• the cost of removing or mitigating the hazard or risk.

No single factor (e.g., cost) should determine the outcome of the assessment. Rather, they should be considered collectively and through a lens of what a reasonable person taking proportionate action to eliminate or minimise risks ought to do in the circumstances. Importantly, if there are multiple controls that achieve the same result in eliminating or minimising a risk, then the most cost-effective option may be chosen. However, choosing a lower-cost option that is less effective on the sole basis that is it cheaper is unlikely to meet the ‘practicable’ test, especially if the severity of the potential harm is significant.

Safety controls and fire risk mitigation

Wind farm owners and operators must have appropriate controls in place to prevent harm to any person, damage to property, and ignition and spread of fire. To ensure this is the case, you should complete a formal safety assessment and implement an effective safety management system. These must be documented and followed, and be available for inspection by Energy Safe when requested, as they form part of the evidentiary base for demonstrating how you are meeting your general duties.

A formal safety assessment involves, for example:

• An identification of hazards that have the potential to cause an incident.
• An assessment of the risks, including the likelihood and consequences of an incident.
• An assessment of the available controls to eliminate or minimise the risks.
• Outline of the controls to be implemented and, if any identified controls will not be applied, the reasoning.
• Performance standards/key performance indicators that must be achieved at a minimum for the implemented controls to be effective.
• Scheduled review and revision of the formal safety assessment to take account of changes in circumstances and/or improvements in the state of knowledge about hazards, risks and controls.

A safety management system should, as a minimum, cover the following:

• Published technical standards and any industry codes applied or to be used in design, construction, commissioning, installation, operation, maintenance and decommissioning activities.
• Minimum competency and training requirements for all roles involved in performing work during the asset lifecycle.
• Safety policies, procedures and systems that are followed and applied (e.g., Permit to work system and asset inspection procedures), together with training to ensure understanding and application.
• Emergency preparedness and response plan.
• Performance standards/key performance indicators that must be achieved at a minimum to ensure effectiveness of implementation of controls, linked to the formal safety assessment.
• Monitoring, auditing and review of the safety policies, procedures and systems and implementing changes arising from those audits and reviews.
  Incident reporting, investigation and reviewing.
• Records management as per legislation and policies.

The following are examples of controls Energy Safe expects all wind farms to have, while wind farm owners and operators must also consider what additional controls are required in their circumstances in accordance with their general duties.

Controls to prevent personal harm, property damage and fire ignition

Effective asset lifecycle management is crucial for operational efficiency and reliability of wind farms, and is vital in ensuring safety obligations are met. Wind farm owners and operators should consider safety during design and equipment selection, and must implement a robust framework for the asset management, failure detection systems and vegetation management to minimise the risk of equipment or electrical faults causing harm to people, property or a fire ignition.

Design and equipment selection

The design and equipment selection stage is the first opportunity to consider what hazards and risks can be eliminated or minimised, to avoid costly mistakes. Wind farm owners and operations should consider the following during the design and equipment selection stage:

Location and surrounding context and conditions

• Site location and placement of wind turbines on a site should consider local environmental conditions including wind patterns and likelihood of extreme weather events that may impact on operation. Also, potential exposure to corrosive elements such as salt or chemicals should be considered.
• Localised fire risk/consequence should also be considered as appropriate, fire prevention measures should be determined having regard to the nature of vegetation near turbines and other equipment.

Turbine specifications

• Turbine specifications should include detailed assessments of electrical system ratings, insulation levels, and compatibility with the wind farm’s grid infrastructure.
• Safety considerations should ensure compliance with international standards such as IEC 61400 series, electrical standards for overvoltage protection, grounding systems, and operational performance under various load conditions.

Safe Design

• Safety in design should incorporate fail-safe systems for electrical faults, including arc fault detection, automatic shutdown systems, and redundancy in critical components.
• Design elements must minimise risks to personnel during the entire lifecycle, from construction through to decommissioning.

Selection of wind turbine generator (WTG) supplier and options

• The choice of WTG supplier should factor in the safety record of their equipment, including features such as lightning protection systems, fire suppression systems, and advanced fault monitoring.
• Equipment options should be evaluated for their compliance with international safety standards, the reliability of electrical systems, and the inclusion of innovative technologies to prevent electrical hazards.

Lightning protection and fire suppression systems

• Effective lightning protection systems must be integrated into the turbine design to safeguard electrical components and reduce the risk from lightning-induced surges.
• Fire suppression systems should be tailored to the turbine's design, addressing potential ignition sources like overheating electrical or mechanical components or insulation failures.

Asset management and maintenance

Wind farm owners and operators should have in place and follow robust asset management and maintenance plans in accordance with installation, operation and maintenance manuals issued by the original equipment manufacturer.

Key asset management activities, a wind farm operator should take into consideration include (but are not limited to):

• Condition monitoring of critical electrical and mechanical components such as gearbox, generator, transformer, bearings and pitch system, hub and blades, power electronic convertor system and brake system.
• Condition assessment for identification of potential risks and failures, and prioritising maintenance or replacement actions to ensure a prompt response to minimise risk.
• Continuous tracking, follow-up inspections and root cause analysis to prevent recurring issues, ensuring safety measures remain effective and reduce the risk of equipment failure, ignition or fire related hazards.
• Maintenance requirements and schedules to proactively manage assets to maximise safety performance and improve the overall safety of the installation.
• Arc fault detection devices, which are circuit breakers that automatically cuts the electricity supply in the event of an arc flash. See Energy Safe’s Arc flash hazard management guideline for more information.
• Lightning protection system to protect critical components including blades, rotor hub and nacelle; from damaging effects of lightning strikes.
• Handling and storage of hazardous chemicals and flammable materials such as transformer oil, lubricants, diesel, refrigerant gas/coolant and batteries; to prevent fire ignition.
• Effective near miss and incident reporting and corrective actions implemented.

Asset failure detection systems

Wind farm owners and operators must implement monitoring systems to quickly detect electrical faults, equipment failures, or short circuits that could result in electric shock or ignite fires. Examples of monitoring system are vibration analysis, acoustic analysis, lubricant analysis, temperature monitoring, current and voltage monitoring, and power output monitoring of electrical and mechanical components.

In addition to the above-mentioned monitoring systems, various inspection tools can be used for defect and failure identification of WTG components. Some of these tools are:

• Thermal imaging for detecting heat signatures that indicate issues such as overheating, electrical faults and insulation problems.
• Drone inspection to capture high-resolution imagery and data for asset integrity assessment.
• Non-destructive testings such as ultrasonic testing, laser scanning and endoscopy inspection to identify cracks, voids and other structural issues.
• Fibre optic sensor monitoring.

Where condition monitoring analysis indicates equipment is at a heightened risk of failure, action must be taken to minimise the risk of component failure. Control or protection systems should not be relied upon as the sole means of mitigating the consequence of equipment failure.

Faults must be immediately addressed, and any fire should be reported to emergency services. Any serious electrical incident arising from the complex electrical installation must also be reported to Energy Safe as required by regulation 401(1)(e) of the Regulations.

Vegetation management

One important control to prevent the ignition and spread of fire is vegetation management around the base of WTGs and other electrical infrastructure such as transformers, substations, power poles and overhead powerlines. The Country Fire Authority’s Guidelines for renewable energy facilities provide further guidance on vegetation management.

The Country Fire Authority’s guidelines specifically require an additional reduced-fuel zone around the base of WTGs. This zone is to be cleared of trees and shrubs (where permitted by the responsible authority) and grass height should not be more than 100mm during the Fire Danger Period.

Wind farm owners and operators are to ensure vegetation is cleared well ahead of, and for the duration of, the declared Fire Danger Period. More information about the declared Fire Danager Period for each municipality is available here: Fire restriction dates.

Controls to minimise consequences of fire ignition

Fire-breaks, fire detection and suppression systems, access to water supply and emergency plans are essential to minimise consequences if a fire ignition occurs.

Fire-breaks

Fire-breaks are where land is cleared of all trees, shrubs, grass and other combustible materials to provide a ‘fuel free’ area. A fire-break of at least ten metres wide must be established and maintained around the base of wind turbines.
Fire-breaks must be non-combustible, constructed of concrete, mineral earth or non-combustible mulch such as crushed rock. They must be free of vegetation and obstructions at all times. No plant or equipment of any kind is to be stored in fire-breaks.

Fire detection and suppression systems

Fire detection and suppression systems minimise the risk of fire due to electrical faults and overheating of components. Wind farm owners and operators must minimise this risk as far as practicable through controls including smoke detectors, heat detectors, gas detectors or flame detectors.
Automatic fire suppression system is the most suitable form of fire suppression in a WTG. Where a fire suppression system is not installed in an existing WTG, the owner and operator should consider whether a retrofit installation would minimise the risk of a fire ignition in the nacelle. Fire suppression systems should be designed and installed in accordance with Australian or equivalent international standards.

Fire water supply

Ready access to an adequate and reliable water supply is critical. Static water tanks should be installed at every wind farm, with at least one 45,000 litre tank at the entrance and additional tanks based on the size of the wind farm. Additional static water tanks of at least 45,000 litre effective capacity should be strategically located throughout the wind farms in line with the emergency management plan that has been developed in consultation with fire authorities.

Emergency management plans

Wind farm owners and operators must have comprehensive emergency management plans with fire response procedures, which have been routinely practised with all relevant personnel and validated/updated as necessary to ensure effectiveness. This should include procedures to isolate parts or all of the electrical installation in case of a fire.
Emergency management plans should be developed in consultation with the local fire authorities and other stakeholders who are involved in responding to emergencies or may be impacted in the case of a fire.

Information for emergency responders

An Emergency Information Book must be developed and available to emergency responders in line with the Country Fire Authority’s Guideline for the provision of emergency information. They must be located in Emergency Information Containers.

The Emergency Information Book must include:

• A description of the premises, its infrastructure and operations.
• Site plans that include the layout of the entire site, including buildings, internal roads, infrastructure, fire protection systems and equipment, dangerous goods storage areas, gas detectors, battery energy storage systems, substations/terminals, grid connections, drains and isolation valves, neighbours and the direction of north.
• Up-to-date contact details for site personnel, regulatory authorities and site neighbours.

Emergency Information Containers must be in accordance with local fire authority requirements.