Grassroots Advocacy: Breath of Fresh Air

With his public comments, NAAA member Ryan Lubben provided a blueprint for applicators to follow by laying out the adverse effects a proposed wind project will have on Minnesota aerial applicators, farmers

A Minnesota aerial applicator did such a thorough job explaining the adverse effects a proposed wind energy project would have on aerial applicators and the farmers they serve in the affected area that his comments to a state official serve as an outstanding model for any aerial applicators grappling with infrastructure projects that could affect their ability to aid area farmers.

Dodge County Wind LLC (DCW) is a subsidiary of NextEra Energy Resources LLC. It is seeking a permit to construct and operate a wind farm of up to 259 megawatts in Dodge and Steele counties in southeast Minnesota. DCW is also seeking a permit to construct approximately 27 miles of a new 161-kilovolt transmission line between a new project substation and an existing substation in Mower County to connect the proposed wind farm to the electrical grid. Without knowing anything further, it’s not hard for someone familiar with aerial application operations to imagine a wind project of that scope could be problematic for aerial applicators.

Ryan Lubben owns West Central Ag-Air Inc. in Fergus Falls, Minnesota, but has frequently spent time applying fungicides and insecticides on farms in a few hours south of Fergus Falls in Dodge County, Minnesota. His comments to an environmental review manager at the Minnesota Department of Commerce systematically explain why the Dodge County Wind Project, as currently planned, would be incompatible with aerial applicators’ ability to safely provide services to farmers located within the wind project’s widespread footprint.

As an opening salvo, Lubben provided facts about the aerial application industry and his company’s operations, but then he went several steps further to highlight the importance of aerial application to farmers and clearly illustrate the unacceptable safety risks the densely clustered wind turbine project would present to aerial applicators. The comments came together rather quickly once he gathered a few Surety maps and overlayed his GPS logs onto them.

Before getting into the hazards of the proposed wind farm, Lubben gave examples of three reasons why growers need to retain the ability to use ag aircraft. The three reasons he cited were efficiency, economics and environmental benefits. For his economics example, Lubben wrote:

Growers in the area typically get an average of a 17 bushel increase in corn yield by applying a fungicide during the tassel stage of development. (Per conversation with a local grower) Using today’s cash corn price of $7.63/bushel, this equates to an increase of $129 per acre. My company would charge roughly $21/acre for this application including chemical. That translates to $108 per acre of profit for the farmer, or a 500% return on investment!

Lubben then moved into the “show” portion of his show-and-tell comments, using his own Surety maps and GPS logs to illustrate to the environmental review manager how the proposed wind turbine construction would jeopardize his and other aerial applicators’ ability to safely enter, exit and return to farmers’ fields in the areas surrounded by the wind turbine clusters and the associated transmission line.

Lubben included the map below of the Dodge County Wind Project area and explained that the GPS flight tracks from his operation for one season were overlaid on to it.

FIG. 1

Next, Lubben illustrated safe turnaround distances needed to make aerial applications safely (see Fig. 2):

FIG. 2
This map shows the GPS flight tracks from a typical field being sprayed. The blue lines are the flight path and the red lines are the actual spray swaths.

As you can see, the aircraft needs quite a large area to have room in order to turn around on the end of the field. In fact, most of the flying takes place outside of the field being treated. The distance needed for this particular aircraft is approximately ¾ of a mile. As a rule of thumb, [the] aircraft needs a full mile of distance on the end of the field to make a safe turn around. Obstacle free turn around areas is critical for these aircraft as the turnaround maneuver is when the aircraft is quite slow and vulnerable to an aerodynamic stall. The applicator must remain focused at this point and cannot be distracted by obstacles, and must have ample room to make the maneuver.
Finally, Lubben included a map showing the proposed locations of the Dodge Center wind turbines in the western portion of the project area (see Fig. 3).

FIG. 3
Each red dot indicates a turbine location. I have highlighted the fields in yellow which would not meet the criteria of having a one mile turn around obstacle free zone on the end of the field. I estimate this map to be a conservative representation of what fields cannot be serviced by ag aircraft. … [T]his is just a portion of the wind farm area. There will be many more fields affected. ¶ Clearly this proposed wind farm will have far reaching impacts on growers in the area in regard to aerial application. Quite frankly the density and random turbine layout will make it impossible for aerial applicators to work safely. Furthermore, it may be impossible for growers in the area to even entice an applicator to come in and do any work in the larger area.

Lubben isn’t opposed to all wind turbine projects and has even had success working around another wind energy site not far from the proposed Dodge County Wind Project. He closed his comments by pointing out the distinctions between the two wind projects:
The incredibly large scope and density of the Dodge County wind turbine layout is what is the issue here. Changes can be made for the area to keep aerial application while still producing wind power. A perfect example of this is the McNeilus wind farm located just two miles south of the Dodge Center airport. This wind farm has the towers lined up and contained in a small area. I have actually been quite comfortable spraying fields in this area because I know I can exit the turbine area in a straight line and make my turn arounds outside of the wind farm. This could easily be done in the proposed wind farm by orientating the wind towers in groups or in straight lines and leaving a mile buffer between groups or lines to allow room for aircraft turn arounds.

Lubben’s full comments are available here.

NAAA applaunds Lubben for his sophisticated yet simplified explanation of the ramifications that ill-planned wind energy projects can inflict on aerial applicators and their farming customers.