With wind turbines significantly higher than they were when the regulations were put in place, Mr Dyer said it was time the state considered increasing the setback distance to 1.5km.

In his annual report, which was tabled in federal parliament last month, Mr Dyer made a series of recommendations about setback distances, fire safety and landholder contracts.

"I think it is time we did revise the Victorian setback distances to at least 1.5km which is my default recommendation, and possibly further for much taller turbines," he said.

The Victorian coalition government introduced a 2km set back when it came to power in 2010, but Labor later changed it to 1km.

He said in the past, the setback distance had been based on potential noise issues.

"Most of them planned around Moyne Shire would be based on the 1km setback distance, or 40 decibels which approximates 1km," Mr Dyer said.

"These permits were done in 2009 and 2010 and probably based around turbines of 1.5MW to 2MW in capacity. It would have been based on tip heights of 120 metres to 150 metres. We're now looking at turbine tip heights of 200 metres or greater."

He said NSW had taken the lead on the issue, basing setback distances on visual amenity such as height of turbines and clustering.

In Queensland the setback is 1.5km, and in South Australia there is a faster planning process for projects with setbacks of 2km, providing an incentive to developers.

Mr Dyer said there had also been a lot of work around making firefighting safer around wind farms, which had resulted in updated guidelines.

Wind turbines did not prohibit firefighting, he said, pointing out that "you need to be a bad pilot to run into a turbine".

However, he said safety protocols should ensure that when wind farms were switched off in the event of a fire, blades should kept in the Y-position to make it safer for pilots.

He said it should be a safety requirement for turbine manufacturers that all wind farms can remotely put their blades in the Y-position.

Mr Dyer said transmission lines and met-masts could be difficult for pilots to see in the event of a fire.

He has recommended that met-masts be painted red and white to improve visibility, or orange marker balls be installed on the met-mast and attached guy-wires to improve safety.

He said the one advantage of the shiny poles of the Salt Creek transmission line from Mortlake to Terang was that they do stand out in the event of a fire.

Mr Dyer also called for Victoria to follow the lead of NSW and make the EPA the compliance body overseeing wind farms when they became operational.

He said this would give them the power to ensure that in the event of a breach, a wind farm company could lose its licence and therefore its right to operate

Expert reports put forward by wind farm companies should be subject to independent auditing to ensure there were no errors, he said.

The commissioner's annual report showed the number of complaints about operating wind farms had fallen with a drop in the number of complaints about health issues, vibration and noise.

Since November 2015, when the commissioner's office first opened, there have been 65 complaints about 11 operating wind farms but last year there were just eight.

He said when a wind farm was operational people realised they were not as bad as they were led to believe, or it could be that people didn't complain because they thought there was nothing they could do.

Most of the complaints the wind farm commissioner received were around planning and community consultation.

Since 2015, there have been 191 complaints about 51 proposed wind farms. Last year there were 95 and most came from Victoria - a rise Mr Dyer said reflected the increase in wind farm activity across the state.

Mr Dyer also said landowners needed to get proper legal advice when it came to making deals with wind farm companies.

"Just because you've been promised a sweetheart deal over the kitchen table doesn't obviate the need for you to get proper legal advice and make sure it's a robust agreement," he said.