Resource Library Category: Americas (3 items)
Documents presented here are not the product of nor are they necessarily endorsed by National Wind Watch. This resource library is provided to assist anyone wishing to research the issue of industrial wind power and the impacts of its development. The information should be evaluated by each reader to come to their own conclusions about the many areas of debate.
Threats from industrial wind turbines to Ontario’s wildlife and biodiversity
Source: Stelling, Keith; and Petrie, Scott
Introduction
The precautionary principle outlined in The Bergen Agreement, signed by Canada in 1990, has become, over the past fifteen years, part of customary international law and has been included in virtually every recently adopted treaty and policy document related to the protection and preservation of the environment. It states: “policies must be based on the precautionary principle. Environmental measures must anticipate, prevent and attack the causes of environmental degradation. Where there are threats of serious or irreversible damage, lack of full scientific certainty should not be used as a reason for postponing measures to prevent environmental degradation”.
The unprecedented rapidity with which industrial wind turbine developments are being proposed and constructed in Ontario, raises major concerns about the efficacy of the Green Energy Act which has allowed and promoted this phenomenon.
1. Adverse environmental effects from industrial wind turbines
Industrial wind turbines do not have a benign environmental foot print as has been claimed.
- Biologists are observing habitat fragmentation and habitat loss, wildlife disturbance and life history disruption when turbines are placed in natural habitats.
- Bird and bat abundance declines at wind turbine sites and this can become more pronounced with time.
- Disruption of ecological links results in habitat abandonment by some species.
- The loss of population vigour and overall density resulting from reduced survival or reduced breeding productivity is a particular concern for declining populations.
- The cumulative effects of multiple on- and off-shore wind developments have not been considered.
- Collision mortality resulting from turbines and new transmission lines is increased during adverse weather conditions and migratory seasons. Especially vulnerable are raptors, passerines (songbirds), monarch butterflies, and bats. The consequential cost to agriculture from loss of pollination and natural insect control is a concern.
- In addition there are serious concerns that turbine noise impacts within- and between-species communications, including predator defence.
- Offshore installations have the added risk of causing waterfowl and waterbird displacement from feeding areas and migratory corridors, contaminant upwelling, and changes in fish communities.
- Placing turbines in close association with coastal wetlands can severely compromise movements and foraging of migratory waterfowl.
2. Ontario bird and bat mortality studies: Wolfe Island
Almost all post operational studies of wildlife mortalities from turbines in Ontario have been unavailable to the public, allowing government and industry to contend that wind turbines kill very few birds. The avian mortality records from Wolfe Island, however, have now disclosed the highest recorded rate of raptor casualties outside California. Each of the 86 industrial wind turbines on Wolfe Island killed an average of 13.4 birds during the first year of operation. Some of the species killed are already experiencing population declines: for example, the Tree Swallow and the Bobolink. Until we have public access to independent mortality studies, we will not know the full impact.
Albert Manville, Senior Wildlife Biologist, Division of Migratory Bird management at the U.S. Fish and Wildlife Service has warned: “The numbers of Bird Species of Conservation Concern killed by wind turbines is increasing, and that’s troubling. These species are already declining, in some cases rather precipitously.”
3. Serious flaws in the Green Energy Act
The government pushed through the Green Energy Act (2009) with negligible legislative or public discussion. The Act exempted renewable energy projects from much of Ontario’s existing environmental legislation.
- One of its amendments to existing statutes, “Schedule G”, exempts renewable energy projects from the Environmental Protection Act, frustrating the purpose of that Act.
- Another, “Schedule K”, removes planning authority from local municipalities and precludes compliance with the Provincial Policy Statement.
- “Schedule L” removes approval rights from Conservation Authorities preventing them from stopping renewable energy projects on their lands.
One of the most troubling provisions of the GEA is the reversal of onus clause that requires citizens to prove a project’s harm to the environment or human health. The Chatham-Kent tribunal demonstrated that confronting government and proponent lawyers is well beyond the financial means of most Ontarians, making a mockery of the Statement of Environmental Principles which insists that the need for public engagement and public consultation is vital to sound environmental decision- making. It also debilitates the Environmental Bill of Rights (1994) which encouraged “enhanced ongoing engagement with the public as part of environmental decision making”.
4. Regulations
An essential flaw in the Regulations is the “fast tracking” provision for environmental assessments which allows the proponents of renewable energy projects to submit their own environmental screening report by hiring an accommodating consultant. Many questions have been raised as to the scientific rigour of these reports:
- Consultants often lack the proper qualifications, specialized knowledge and technical expertise to provide sound advice (for example, pertaining to waterfowl).
- Studies lack scientific rigour and fail to adequately consider existing peer reviewed literature.
- There is an insufficient use of local expert knowledge during the planning process and not enough use of available/historic data.
- Relative to Europe and the United States, there has been insufficient pre- construction monitoring at proposed wind turbine sites in Ontario (often days/months as opposed to years).
- Post-construction studies lack scientific rigour and are not standardized.
- Times chosen to make observations are often unsuitable (e.g. after or before
migratory seasons and during daylight hours while most migrations of birds
and bats take place at night). - Radar observations are not being used to monitor nocturnal migrations and
aerial observations are not being used for determining waterfowl populations even though these are the best methods for accurate assessment. - Most “studies” are based on casual observations done over an insufficient number of days, seasons, and weather conditions and they do not include
the multi-seasonal or multi-year observations necessary to determine effects
on fluctuating populations. - The methodology of the reports has been questioned and serious omissions pointed out: for example, they fail to set any a priori criteria for determining if the wind development in question will have adverse impacts on birds or bats.
Proponent-commissioned reports have generally been rubber-stamped by the Ministry of the Environment and the Ministry of Natural Resources. The Wolfe Island project, for example, was approved despite its location on a major migratory bird corridor adjacent to provincially significant wetlands, staging areas and an Important Bird Area (IBA).
Although the industry continues to claim that it avoids placing turbines near sensitive habitats, far too many projects have been constructed, approved or proposed near critical ecosystems which support threatened species, provincially significant ANSIs and provincially significant wetlands—e.g. Wolfe Island, Ostrander Point, Arran Lake, Point Pelee National Park, coastal wetlands associated with Lake St. Clair, and Manitoulin Island among them. Numerous wind turbines have been proposed for construction in close association with coastal wetlands along the lower Great Lakes (Lakes St. Clair, Erie, and Ontario). Coastal wetlands provide critically important staging habitat for nearly 30 species of migratory waterfowl. In fact, millions of waterfowl use these wetlands each spring and fall to rest, feed and acquire the body fat necessary for migration and reproduction. Approximately 85% of our coastal wetlands have already been drained and converted to agriculture and urban development; those that remain are regularly being compromised by additional human impacts and invasive species. Consequently, it is critically
important that we do our utmost to conserve and protect all remaining coastal wetlands.
There are other problems and inconsistencies with the Regulations and Guidelines.
- The 120 metre setback from Significant Wildlife Habitat (compared to 550 metres from human habitations) is not biologically defensible. The regulations even allow proponents to place developments within Significant Wildlife Habitats when they claim they can “mitigate” adverse effects.
- The “Bird Habitat Assessment Process” requires post construction monitoring of avian mortality but does not require an adequate assessment of wildlife displacement.
- Cumulative impacts of onshore and offshore industrial wind turbines (including those being proposed for American waters) are not being considered.
- Guidelines don’t consider bird mortality to be significant until 18 birds/turbine/year are killed. This is 7.2 times the NA average and is not biologically defensible.
- Guidelines don’t consider the mortality of raptors of provincial conservation concern (i.e. Bald Eagles) to be significant unless 0.2 raptors/ turbine/year are killed. Therefore, a development with 100 turbines that killed 19 Bald Eagles per year would not require mitigation.
- Community consultation (a requirement of the Green Energy Act) has been a dismal failure with proponents ignoring and evading community concerns
and refusing to hold public consultation meetings in preference for open house product showcases.
5. Advice of international biologists
Repeatedly biologists around the world have stated the obvious and simple warning: industrial wind turbines must be kept well away from sensitive natural habitats, including important migratory corridors.
- “Avoid locating wind farms in regional or internationally important bird or bat areas and/or migration routes”. Everaert and Kuijken 2007.
- “Developers should avoid sites that are important to wildlife”. –Dr. Mark Avery, Royal Society for the Protection of Birds, U.K.
- “Wind turbine developments should not be placed within 1000 meters of waterfowl roost sites; not be placed within 1 kilometre of staging areas; not be placed in flight corridors between roosts and feeding grounds; not be placed on major migratory corridors, and not be erected in areas where the wind turbine development +500 m buffer zone occupies more than 1% of the known feeding areas at a site; not be placed in agricultural fields traditionally used by large flocks of waterfowl”. –Bjarke Laubek, M.Sc., Waterfowl Biologist with extensive experience working on waterfowl and turbine placement in Denmark.
- “Wind turbine developments should not be sited near populations of birds of conservation importance, particularly Anseriformes”. –Stewart, et al. 2004.
- “Avoid placing turbines in documented locations of protected wildlife, known local bird migration pathways or near wetlands and staging areas and avoid known daily movement flyways between roosting and feeding
areas, as well as bat breeding and nursery colonies or migration corridors. –U.S. Fish and Wildlife Service - “Wind turbine developments must no longer be built in any natural areas”. –Spanish Ornithological Society.
- “If we are to save our emblematic bird species from this new threat, it is urgent to impose a moratorium on windfarm construction and to call for a fully independent commission to investigate the whole windfarm matter, starting with the effectiveness of this intermittent, unreliable, and ruinous form of energy”. –Mark Duchamp, Save the Eagles International.
6. Recommendations
Revision of the Green Energy Act and its Regulations and guidelines is imperative to bring it into compliance with pre-existing environmental protection legislation.
- Amendments must be made to loopholes in the Act which exempt renewable energy projects from the Planning Act (and Provincial Policy Statements), the Environmental Protection Act, and the Conservation Authorities Act, and Regulations which change the purpose of the Statement of Environmental Principles and the Environmental Bill of Rights.
- Regulations must be revised to reflect the recommendations of scientists and biologists as outlined above. Regulations, guidelines and procedures must be revised to require independent mortality and displacement studies and avoid the problems related to proponent-commissioned environmental surveys outlined above. Biologically defensible setback restrictions and mortality levels must be established for wildlife habitats and migratory corridors.
- Industrial wind turbines must not be placed within 2 km of coastal and other provincially significant wetlands and should not be placed on major migratory corridors or in agricultural fields traditionally used by large concentrations of wildlife.
- All post and pre-construction monitoring must be made available to the public to allow for participation in environmental decision making as required under the Statement of Environmental Principles and the Environmental Bill of Rights.
The onus of proof of environmental damage must be reversed to make developers of renewable energy projects responsible for their actions and bring these projects into compliance with the Provincial Policy Statement.
7. Questionable effectiveness in saving GHG emissions
Here we discuss wildlife issues related to poorly regulated industrial wind turbine development but the rationale for building the turbines should also be examined.
The ideology behind industrial wind turbine installation has not been validated by experience. It is now apparent that wind turbines will not diminish Ontario’s carbon footprint just as they have failed to do anywhere else in the world.
Government advisors and ministers did not listen to the warnings of electricity generation professionals who pointed out the practical complications of adding intermittent and unpredictable wind energy to the grid. Stability can only be maintained by running fossil-fuelled plants inefficiently on standby to back up all potential wind production.
European experience has demonstrated that coal plants cannot be closed in exchange for non-base load wind energy. Germany, which has installed over 20,000 industrial wind turbines, has increased CO2 and other GHG emissions and new coal plants have had to be built to compensate for the destabilizing effect of wind energy. Ontario is building more gas plants for this same reason.
Bennet & McBee (2011) were the first to systematically assess the emission reduction performance of wind generation based on hourly generation and emissions data from Colorado and Texas in the Bentek study. It shows that previous claims were significantly overstated and that actual CO2 reductions are either so small as to be insignificant or too expensive to be practical.
Summary
The dwindling areas of wetland and other specialized ecosystems which provide habitat for threatened and endangered species are especially vulnerable to disturbance and degradation from this form of rural industrialization. Migratory avian species including raptors, waterfowl, waterbirds, passerines and bats are particularly vulnerable to displacement from critical habitats and collision mortality. Government and developers have downplayed the negative environmental footprint of wind turbines. However, as developments proliferate, post construction monitoring points to unforeseen cumulative effects and many looming
environmental concerns. Ontario’s Green Energy Act with its inadequate regulations and guidelines governing the siting of renewable energy installations is urgently in need of revision. Better information on the effects of industrial wind turbines must be obtained through rigorous study and the precautionary principle of the Bergen Agreement adhered to before further construction proceeds and incalculable irreversible damage is done to Ontario’s natural heritage.
Keith Stelling, MA, MNIMH, Dip. Phyt., MCPP
Friends of Arran Lake
Central Bruce-Grey Wind Concerns Ontario
Scott Petrie, PhD
Executive Director, Long Point Waterfowl
Adjunct Professor, University of Western Ontario
References
Barrios, L., and A. Rodriguez. 2004. Behavioural and environmental correlates of soaring bird mortality at on-shore wind turbines. Journal of Applied Ecology. 41:72-81.
Bennet, P., and B. McBee. 2011. The Wind Power Paradox: Bentek Market Alert. Crowder, A.A., and J.M. Bristow. 1988. The future of waterfowl habitats in the Canadian lower Great Lakes wetlands. Journal of Great Lakes Research. 14:115-127.
Dennis, D.G.,, G.B. McCullough, N.R. North, and R.K. Ross. 1984. An updated assessment of migrant waterfowl use of Ontario shorelines of the southern Great Lakes. Pages 37-42in Waterfowl Studies in Ontario, S.G. Curtis, D.G. Dennis and H. Boyd, editors. Canadian Wildlife Service Occasional Paper No 54.
Desholm, M. 2006. Wind farm related mortality among avian migrants – a remote sensing study and model analysis. Ph.D. Thesis, National Environmental Research Institute, Denmark.
Everaert,J.,and E.Kuijken.2007.WindturbinesandbirdsinFlanders(Belgium): Preliminary summary of the mortality research results: Belgian Research Institute for Nature and Forest.
Frondel, M., N. Ritter, C. Vance, F. Scheffer, and C. Schmidt. 2009. Economic impacts from the promotion of renewable energies: The German experience. Final Report: Rheinisch-Westfa?lisches Institut fu?r Wirtschaft sforschung (Rhine-Westphalia Institute for Economic Research).
Herdendorf, C.E. 1992. Lake Erie coastal wetlands: an overview. Journal of Great Lakes Research. 18:533-551.
Irish Electricity Supply Board (ESB). 2004. Impact of Wind Power Generation in Ireland on the Operation of Conventional Plant and the Economic Implications: ESB National Grid.
Kingsley, A., and B. Whittam. 2005. Wind Turbines and Birds: A Background Review: Environment Canada / Canadian Wildlife Service, 81 pages.
Kunz, T., E. Arnett, W. Erickson, A. Hoar, G. Johnson, R. Larkin, M. Strickland, R. Thresher, and M. Tuttle. 2007. Ecological impacts of wind energy development on bats: questions, research needs, and hypotheses: Journal of Wildlife Management 71:2449–2486; DOI: 10.2193/2007-270.
Liik, O., R. Oidram, and M. Keel. 2003. Estimation of real emissions reduction caused by wind generators: Tallinn Technical University, Estonia.
Manville, A.M. 2005. Bird strikes and electrocutions at power lines, communication towers, and wind turbines: state of the art and state of the science – next steps toward mitigation: Proceedings 3rd Internatl. Partners in Flight Conference. USDA Forest Service Gen. Tech. Rep. PSW-GTR-191, Vol. 2: 1051-1064.
Ontario Power Authority (OPA). October 2007. Integrated Power System Plan.
Petrie, S.A. 1998. Waterfowl and Wetlands of Long Point Bay and Old Norfolk County: Present Conditions and Future Options for Conservation. Unpublished Norfolk Land Stewardship Council Report. Long Point Waterfowl, Port Rowan, Ontario.
Petrie, S.A., S. Badzinski, and K.L. Wilcox. 2002. Population trends and habitat use of Tundra Swans staging at Long Point, Lake Erie. Waterbirds: 25:143-149.
Petrie, S.A., and K.L. Wilcox. 2003. Migration chronology of Eastern Population Tundra Swans. Canadian Journal of Zoology. 81: 861-870.
Prince, H.H., P.I. Padding, and R.W. Knapton. 1992. Waterfowl use of the Laurentian Great Lakes. Journal of Great Lakes Research. 18:673-699.
Schummer, M. L. 2005. Comparisons of resource use by Buffleheads, Common Goldeneyes and Long-Tailed Ducks during winter on northeastern Lake Ontario. Ph.D. Dissertation. University of Western Ontario. London, Ontario.
Stewart, G. B., and A.S. Pullin. 2004. Effects of wind turbines on bird abundance; Systematic Review No.4: Centre for Evidence-based Conservation, University of Birmingham, England, 49p.
Re: Wind Turbine Health Impact Study: Report of Independent Expert Panel
Source: Krogh, Carmen
The purpose of this letter is to respond to the Wind Turbine Health Impact Study: Report of Independent Expert Panel of January 2012 that was prepared for the Massachusetts Department of Environmental Protection, Massachusetts Department of Public Health.
I would like to share excerpts from Ontario, Canada experiences regarding the serious risks to health that can occur when industrial wind turbines are sited in close proximity to residents.
As background, I have held senior executive positions at a teaching hospital, a professional organization and Health Canada (PMRA). I am a former Director of Publications and Editor in Chief of the Compendium of Pharmaceuticals and Specialties (CPS), the book used by physicians, nurses, and health professionals for prescribing information in Canada.
Contact with those experiencing adverse health effects which correlated with the onset of industrial wind turbine operations, inspired my research on the topic.
I volunteer my time and expenses, self support research and other activities such as education regarding the science related to wind turbine health effects. Some of my activities include meeting with authorities, locally, provincially and federally.
A colleague and I initiated a self reporting health survey in March 2009. WindVOiCe (Wind Vigilance for Ontario Communities) follows the principles for Health Canada’s Canada Vigilance Programs for self reporting suspected adverse events for prescription and consumer products, vaccines and other. The results of this research have been published in a special edition of a peer reviewed scientific journal. [1]
I have also researched societal impacts relating to this topic. This article has also been published in a peer reviewed journal. [2]
Based on several years of investigation: “My research demonstrates that IWTs were initially welcomed into communities. The reported adverse impacts were unexpected …” and “In addition to physiological and psychological symptoms there are individuals reporting adverse impacts, including reduced well-being, degraded living conditions, and adverse societal and economic impacts. These adverse impacts culminate in expressions of a loss of fairness and social justice.” [3]
Several months after the publication of my article, Shepherd et al noted:
“… wind turbines were initially welcomed by many communities due to their environmental credentials …”
“… residents living within 2 km of a turbine installation reporting lower overall quality of life, physical quality of life, and environmental quality of life. Those exposed to turbine noise also reported significantly lower sleep quality …” [4]
Quality of life and social well being are important health considerations. I have found the stressors occurring within the home and community environment as the result of a change in the environment, e.g. industrial wind turbines, are contributing to adverse health effects. To date, there is no mitigation available to those suffering.
There is ample evidence regarding the health risks associated with industrial wind turbines.
In 2009 The American Wind Energy Association and Canadian Wind Energy Association funded experts to conduct a literature review which explicitly identifies a causal link (through annoyance) to the reported adverse health effects.
The authors of the industry convened report determined the documented “wind turbine syndrome“ symptoms (sleep disturbance, headache, tinnitus, ear pressure, dizziness, vertigo, nausea, visual blurring, tachycardia, irritability, problems with concentration and memory, and panic episodes associated with sensations of internal pulsation or quivering when awake or asleep are symptoms) “are not new and have been published previously in the context of “annoyance”” and are the “well-known stress effects of exposure to noise”. [5]
This acknowledgement cannot be ignored.
Peer reviewed studies consistently acknowledge wind turbine noise is perceived to be more annoying than transportation noise or industrial noise at comparable sound pressure levels. [6]
Now that the experts funded by members of the wind industry have identified a causal link steps must be taken to ensure these health outcomes are avoided.
Three of the authors of this industry report testified at an Ontario Environmental Review Tribunal which was conducted under oath. 26 expert witnesses from around the world testified (10 Appellants, 16 Respondents – Ministry of Environment and Suncor Inc developer). The evidence and testimony of this tribunal is further evidence that wind turbines can harm human health.
An Ontario Freedom of Information request and peer reviewed articles published during 2011 should also be considered.
I have attached legal opinions and citations regarding the evidence including a summary which I presented to the Standing Senate Committee on Energy, the Environment and Natural Resources, October 18, 2011.
The Ontario Environmental Review Tribunal Decision, July 18, 2011, stated:
“This case has successfully shown that the debate should not be simplified to one about whether wind turbines can cause harm to humans. The evidence presented to the Tribunal demonstrates that they can, if facilities are placed too close to residents. The debate has now evolved to one of degree.” [7]
A Freedom of Information request from the Ontario Ministry of Environment notes:
“It appears compliance with the minimum setbacks and the noise study approach currently being used to approve the siting of WTGs will result or likely result in adverse effects …” [MOE memorandum, Ontario Senior Environmental Officer, April 9, 2010]
The Ontario Ministry of Environment documents are available at www.windyleaks.com
I note that the Wind Turbine Sound and Health Effects – An Expert Panel Review – December 2009 states that: wind turbine sound/noise may cause annoyance (p. 5-3), stress (p. 4-3, 4-10) and sleep disturbance (p. 4-3), which may have other consequences (p. 4-3, 4-10) [8] Annoyance may seem of little consequence in everyday language; however, in clinical terms it has negative health consequences. The term annoyance is acknowledged as an adverse health effect.
The indirect pathway is often given a low priority regarding this topic. The Environmental Review Tribunal expressed concerns with respect to The Potential Health Impact of Wind Turbines (Chief Medical Officer of Health (CMOH) Ontario Report) – May 2010.
“… about the Director’s apparent lack of consideration of indirect health effects and the need for further work on the MOE’s practice of precaution …” [9]
To better understand the importance of the indirect pathway, please note the World Health Organization noise schema below. Symptoms being reported are through the indirect pathway. Testimony under oath during the Environmental Review Tribunal acknowledged that the indirect pathway was not considered by the CMOH. [10]
Statements indicating there is no evidence of a “direct” causal link may be accurate but is also an incomplete assessment of the health risks. The indirect pathway of noise annoyance, sleep disturbance and stress leads to consequences (cardiac). When one focuses on “direct” effect one omits consideration of an equally significant part of the health equation ie indirect effects.
Some have referenced that World Health Organization Noise Guidelines (2009) recommend a 40 dB noise level for industrial wind turbines; however, this is an incorrect interpretation of these guidelines. The WHO guidelines are based on road, rail and air craft noise, not on industrial wind turbine noise. Peer reviewed research has shown wind turbine noise is more annoying than these three types of noise at comparable sound levels. Therefore the premise of 40 dB applying to wind turbines is not justified – research [11] and MOE field officer [12] propose 30 to 32 dB.
To conclude, a December 2010 report commissioned by the Ontario Ministry of Environment and submitted as evidence during the Environmental Review Tribunal and just recently released by the Ministry notes:
“The audible sound from wind turbines, at the levels experienced at typical receptor distances in Ontario, is nonetheless expected to result in a non-trivial percentage of persons being highly annoyed. As with sounds from many sources, research has shown that annoyance associated with sound from wind turbines can be expected to contribute to stress related health impacts in some persons.” [13]
This report also states
“Stress symptoms associated with noise annoyance, and in particular low frequency annoyance, include sleep interference, headaches, poor concentration, mood swings …” [14]
During 2011, there has been significant progress in acknowledging the harm that can occur when industrial wind turbines are sited too close to residents.
Consideration should be given to recent Australian movements towards a minimum 2 km setback (see Senate slides attached for references). Furthermore in January 2012 the National Health and Medical Research Council reaffirmed their position that authorities are instructed to maintain a precautionary approach for this issue.
Social well-being is acknowledged to be a determinant of health: “Health is a state of complete physical, mental and social well-being and not merely the absence of disease or infirmity” (World Health Organization [WHO], 1948). Many jurisdictions, including the Canadian federal, provincial, and territorial governments and health officials have accepted WHO’s definition of health (Health Canada, 2004, vol. 1, p. 1-1).” [15]
I am not certain whether jurisdictions in the United States of America have accepted the WHO definition; however, it is widely accepted that social, physical and mental health should be evaluated when assessing adverse health effects.
The symptoms have been acknowledged through testimony under oath, and / or disclosure evidence and/or witness statements and through other references as briefly provided in this letter.
There are some research gaps regarding the mechanism and the siting distances and noise levels that will protect human health.
To conclude: “In all cases, noise should be reduced to the lowest level achievable in a particular situation. Where there is a reasonable possibility that public health will be damaged, action should be taken to protect public health without awaiting full scientific proof.” [16]
I believe we are at the stage where public health officials must acknowledge there are some suffering from exposure to industrial wind turbines. Furthermore it is time to move beyond repetitive literature reviews. There is an urgent need to conduct the research to determine the siting parameters including setback distances and noise levels to ensure protection of health.
~~~
January 19, 2012
Ms Carmen Krogh, BScPharm
Ontario, Canada
krogh/email.toast.net
[1] Krogh, CME, Gillis, L, Kouwen, N, and Aramini, J, (2011), WindVOiCe, a Self-Reporting Survey: Adverse Health Effects, Industrial Wind Turbines, and the Need for Vigilance Monitoring, Bulletin of Science Technology & Society 2011 31: 334, DOI: 10.1177/0270467611412551, http://bst.sagepub.com/content/31/4/334
[2] Krogh, CME, (2011), Industrial Wind Turbine Development and Loss of Social Justice? Bulletin of Science Technology & Society 2011 31: 321, DOI: 10.1177/0270467611412550, http://bst.sagepub.com/content/31/4/321
[3] Krogh, CME, (2011), Industrial Wind Turbine Development and Loss of Social Justice? Bulletin of Science Technology & Society 2011 31: 321, DOI: 10.1177/0270467611412550, http://bst.sagepub.com/content/31/4/321
[4] Evaluating the impact of wind turbine noise on health-related quality of life by Daniel Shepherd, David McBride, David Welch, Kim N. Dirks, Erin M. Hill. Noise & Health, September-October 2011, 13:54,333-9
[5] Colby, W. D., Dobie, R., Leventhall, G., Lipscomb, D. M., McCunney, R. J., Seilo, M. T., & Søndergaard, B. (2009). Wind turbine sound and health effects: An expert panel review 2009. Prepared for American Wind Energy Association and Canadian Wind Energy Association. http://www.canwea .ca/pdf/talkwind/Wind_Turbine_Sound_and_Health_Effects.pdf
[6] Pedersen, E., Bakker, R., Bouma, J., & van den Berg, F. (2009), Response to noise from modern wind farms in the Netherlands, Journal of the Acoustical Society of America, 126, 634-643
[7] Case Nos.: 10-121/10-122 Erickson v. Director, Ministry of the Environment Environmental Review Tribunal, Decision, p 207
[8] Colby, W. D., Dobie, R., Leventhall, G., Lipscomb, D. M., McCunney, R. J., Seilo, M. T., & Søndergaard, B. (2009). Wind turbine sound and health effects: An expert panel review 2009. Prepared for American Wind Energy Association and Canadian Wind Energy Association. http://www.canwea .ca/pdf/talkwind/Wind_Turbine_Sound_and_Health_Effects.pdf
[9] Case Nos.: 10-121/10-122 Erickson v. Director, Ministry of the Environment Environmental Review Tribunal, Decision, p 206
[10] Case Nos.: 10-121/10-122 Erickson v. Director, Ministry of the Environment Transcript of Dr. G. Rachamin, Mar, 4, 2011 [1] p. 211, [2] p. 216
[11] Thorne, B, (2011), The Problems With ”Noise Numbers” for Wind Farm Noise Assessment, Bulletin of Science Technology & Society 2011 31: 262, DOI: 10.1177/0270467611412557, http://bst.sagepub.com/content/31/4/262
[12] MOE memorandum, Ontario Senior Environmental Officer, April 9, 2010
[13] HGC (2010) Low frequency Noise and Infrasound Associated with Wind Turbine Generation Systems, A Literature Review, Ontario Ministry of Environment RFP December 2010
[14] HGC (2010) Low frequency Noise and Infrasound Associated with Wind Turbine Generation Systems, A Literature Review, Ontario Ministry of Environment RFP December 2010
[15] World Health Organization. (1948). Preamble to the constitution of the World Health Organization as adopted by the InternationalHealth Conference, New York, 19-22 June, 1946; signed on 22July 1946 by the representatives of 61 States (Official records of theWorld Health Organization, no. 2, p. 100) and entered into force on7 April 1948. Cited Krogh, CME, (2011), Industrial Wind Turbine Development and Loss of Social Justice? Bulletin of Science Technology & Society 2011 31: 321, DOI: 10.1177/0270467611412550, http://bst.sagepub.com/content/31/4/321
[16] World Health Organization. (1999). Guidelines for community noise. Geneva; OMS, 1999, p 94. Ilus, Berglund, B., Lindvall, T., and Schwela, D. H.
To:
Jeffrey M. Ellenbogen, MD; MMSc Assistant Professor of Neurology, Harvard Medical School Division Chief, Sleep Medicine, Massachusetts General Hospital jeffrey_ellenbogen@hms.harvard.edu
Sheryl Grace, PhD; MS Aerospace & Mechanical Engineering Associate Professor of Mechanical Engineering, Boston University sgrace@bu.edu
Wendy J Heiger-Bernays, PhD Associate Professor of Environmental Health, Department of Environmental Health, Boston University School of Public Health Chair, Lexington Board of Health Email unavailable
James F. Manwell, PhD Mechanical Engineering; MS Electrical & Computer Engineering; BA Biophysics Professor and Director of the Wind Energy Center, Department of Mechanical & Industrial Engineering University of Massachusetts, Amherst manwell@ecs.umass.edu
Dora Anne Mills, MD, MPH, FAAP State Health Officer, Maine 1996–2011 Vice President for Clinical Affairs, University of New England Email unavailable
Kimberly A. Sullivan, PhD Research Assistant Professor of Environmental Health, Department of Environmental Health, Boston University School of Public Health Email unavailable
Marc G. Weisskopf, ScD Epidemiology; PhD Neuroscience Associate Professor of Environmental Health and Epidemiology Department of Environmental Health & Epidemiology, Harvard School of Public Health mweissko@hsph.harvard.edu
Copy:
Susan L. Santos, PhD, FOCUS GROUP Risk Communication and Environmental Management Consultants info@focusgroupconsulting.com
Wind Turbine Health Impact Study Is Junk Science
Source: Hartman, Raymond
[Wind Turbine Health Impact Study: Report of Independent Expert Panel, January 2012, prepared for: Massachusetts Department of Environmental Protection, Massachusetts Department of Public Health]
Junk Science: What Is It?
“Junk science is faulty scientific data and analysis used to advance special interests and hidden agendas.”
General Examples
“Government regulators may use junk science to expand their regulatory authority, increase their budgets or advance the political agenda of elected officials.”
“Businesses may use junk science to bad-mouth competitors’ products, make bogus claims about their own products, or to promote political or social change that would increase sales and profits.”
“Politicians may use junk science to curry favor with special interest groups, to be politically correct or to advance their own personal political beliefs.”
Specific Real-World Examples
The Tobacco Research Institute
- It was funded by the big tobacco companies.
- It produced “scientific research” for 50 years or more “demonstrating” that smoking was good, or at least not bad, for people.
- Over time, as doctors and patients complained that smoking caused lung cancers and cardiovascular diseases, the Tobacco Research Institute produced more “scientific research” demonstrating that something else caused the disease.
→ The “research” was Junk Science.
→ It was untrue, manipulated and unreliable.
→ The “research” caused disease and death.
Asbestos Manufacturers
- Asbestos was used for decades in shipbuilding, construction and a variety of other trades.
- Those workers installing and working with asbestos were told for decades that research demonstrated that the workers were safe.
- Workers were not safe.
- Asbestos caused innumerable cases of cancer – mesothelioma.
- The asbestos manufacturers put forward research “demonstrating” that the cancers were not caused by the asbestos.
→ The “research” was Junk Science.
→ It was untrue, manipulated and unreliable.
Manufacturers of DDT
- DDT was first used as a pesticide in the 1940s.
- It was claimed to be a successful and safe pesticide.
- The US government began banning DDT for particular uses in the 1960s.
- It was banned outright in 1972.
→ The original “research” was Junk Science.
→ It ignored the health and environmental risks of DDT.
The Wind Turbine Health Impact Study Is Junk Science
Deval Patrick sponsored and defends the study which “found no scientific evidence or medical studies to prove that living near a wind turbine has adverse impacts on people’s health, though it acknowledged further study is needed to look at health impacts stemming from ‘annoyance’ for residents who live near turbines.” [State Capitol Briefs, Afternoon Edition, Thursday, January 19, 2012, State House News Service]
The conclusions reached by the study are utterly and profoundly dishonest.
The study is labeled a “Report of Independent Expert Panel.”
- The panel was not independent.
- Several “experts” have pro-wind industry connections. [For one important example, I understand that Dr. James Manwell’s Wind Energy Center is heavily funded by the Commonwealth. I believe that it is therefore impossible for him to offer a neutral opinion on the health effects of industrial wind turbine installations, given the Commonwealth’s obvious infatuation with wind energy.]
- The Panel is no more qualified or expert than the substantial number of opponents, including Dr. Pierpont and myself.
[NWW: Perhaps much less so — see this Jan. 28 letter running down the members of the panel.]
The Panel relies primarily on an inexplicably small number (4) of published research papers, out of 100s that are available.
- Two Swedish research papers, one Dutch research paper and one New Zealand Research paper.
- The Panel dismisses for unsupported reasons all the other studies.
- In statistical modeling, this is called “cherry picking” – choosing only those studies that support a desired conclusion.
The sizes of the wind turbines studied are quite small.
- The turbines studied were only 164-213 feet tall.
- These are much smaller than those proposed for Mount Massaemet which are nearly 500 feet tall.
- Noise effects increase with the size of the turbine blades.
The data, models and statistical analyses in these papers are flawed, in ways explicitly noted by the Panel.
- The Panel notes: “The peer-reviewed papers have weaknesses, including the cross sectional designs and sometimes quite low response rates (p. 28).”
- The Panel further notes: “The model from which this conclusion was drawn, however, imposed a linear relation on the association between noise level category and annoyance. But … it appeared that the relation might not be linear (p. 18).”
- In statistical modeling, the imposition of a linear relationship when it is invalid is called specification bias.
→ When present, the model and analysis are wrong.
→ The studies introduce a multiplicity of other possible factors, all of which interfere with properly analyzing and estimating the impact of the primary factor upon health – turbine noise.
The Panel mentions but ignores the findings of the most recent analysis by the authors of two of their chosen studies (the Swedish studies). This most recent study contradicts the Panel’s conclusions as follows [as noted explicitly by the Panel at page 19]:
- “A more intricate statistical model of the association between turbine noise levels and annoyance that used the data from both Swedish studies … suggested a significant association between noise levels and annoyance even after considering other factors.”
- Why didn’t the Panel consider this third study by the same authors, which used better analytic and statistical methods?
→ This exclusion is unprofessional, unscientific and outright dishonest.
→ This is Junk Science.
The Panel identifies the preferred type of study – time-series analyses, looking at families and households before and after the industrial turbines are put into operation → “A Before-and-After Study.”
- The Panel notes “Cross-sectional studies [which the Panel uses] lack the ability to determine the temporality of cause and effect; in the case of these kinds of studies, we cannot know whether the annoyance level was present before the wind turbines were operational from a cross sectional study design.”
- Why didn’t the Panel look at time-series experiences that have occurred in New England – Maine, Vermont, and Massachusetts? [I understand that the ISO-NE seasonal-claimed capability spreadsheet identifies the following industrial wind turbine (IWT) sites which could have been used for “Before-and-After” studies: 19 IWT projects in Massachusetts; 9 IWT projects in Maine, including Mars Hill which is outside the ISO-NE area and so is not listed on the ISO's spreadsheet; 3 IWT projects in Rhode Island; 2 IWT projects in New Hampshire; and 2 IWT projects in Vermont.]
- This is the most natural set of experiments to be done and is easily available.
- Is the reason because they knew what such experiments would find – that Industrial Wind Turbines cause sleep problems and severe annoyance, leading to health problems?
The Panel does admit to finding the following:
- “Wind turbines can produce unwanted sound (referred to as noise) during operation (p. ES-4)”
- “The whooshing that is heard is NOT infrasound … [It] is at higher frequency … It is important to note then that when a complaint is tied to the thumping or whooshing that is being heard, the complaint may not be about ILFN at all even if the complaint mentions low frequency noise. Kamperman et al. (2008) state that, ‘It is not clear to us whether the complaints about ‘low frequency’ noise are about the audible low frequency part of the ‘swoosh-boom’ sound, the once-per-second amplitude modulation … of the ‘swoosh-boom’ sound, or some combination of the two (p. 13).” [Emphasis added. These are precisely the sounds described by Neil Anderson from Falmouth.]
- “Most epidemiologic literature on human response to wind turbines relates to self-reported ‘annoyance’ … (p. ES-5).”
- “A very loud wind turbine could cause disrupted sleep, particularly in vulnerable populations, at a certain distance, while a very quiet wind turbine would not likely disrupt even the lightest of sleepers at that same distance (p. ES-6).”
The Panel however concludes that there is insufficient evidence that industrial wind turbines will have any effects upon residents near the installation. It states:
- “There is limited evidence from epidemiologic studies suggesting an association between noise from wind turbines and sleep disruption. In other words, it is possible that noise from some wind turbines can cause sleep disruption. … But there is not enough evidence to provide particular sound-pressure thresholds at which wind turbines cause sleep disruption (p. ES-5 and ES-6).”
- “Whether annoyance from wind turbines leads to sleep issues or stress has not been sufficiently quantified. While not based on evidence of wind turbines, there is evidence that sleep disruption can adversely affect mood, cognitive functioning, and overall sense of health and well-being (p. ES-6).”
- “There is insufficient evidence that the noise from wind turbines is directly (i.e., independent from an effect on annoyance or sleep) causing health problems or disease (p. ES-6).”
Reflect closely on this language.
- Noise causes annoyance and disrupts sleep.
- Annoyance and sleep disruption causes stress and disease states.
- While the evidence demonstrates that industrial wind turbines cause annoyance and disrupt sleep, the Panel finds it is insufficient or an indirect cause.
- Do you believe that assertion?
The Panel’s report and conclusions are JUNK SCIENCE.
What does this mean for Shelburne?
- There will be wind turbine noise.
- Prepare yourself for the “‘swoosh-boom’ sound, the once-per-second amplitude modulation … of the ‘swoosh-boom’ sound, or some combination of the two.” [See the Impact Study, p. 13, cited above.]
- This noise will disrupt the sleep of an unknown number of Shelburne and Buckland residents.
- This noise will cause low-to-severe cases of “annoyance,” every day, every hour, every minute for an unknown number of residents.
- The non-stop annoyance and sleep disruption will cause stress and disease states for an unknown number of residents.
- This noise will affect many Shelburne residents in precisely the same fashion as has been found in Falmouth, Vinalhaven and across New England.
- Are you ready to be guinea pigs for an experiment in which we suffer the possible consequences while outside developers make hundreds of millions of dollars in subsidies, and then leave town?
Raymond S. Hartman is a Shelburne resident, living in the Patten District: ‘I have a BA from Princeton University and a Masters and PhD from MIT. All of my degrees are in mathematical economics. I have been a member (Associate Professor) of the faculties of MIT, Boston University, and University of California, Berkeley. I have published more than 100 peer-reviewed articles and contract research using statistical and mathematical models, methods, and data. I am currently President and Director of Greylock McKinnon Associates, an economic consulting firm specializing in analysis in support of litigation. Indeed, I regularly have testified as an expert witness on behalf of the Massachusetts Attorney General’s office in a variety of matters, including the 1995-1996 tobacco litigation (the result of which the Commonwealth received billions of dollars in settlement from “Big Tobacco”); litigation against large drug companies for defrauding the Massachusetts Medicaid program (2008-2011); the restructuring of the electric power industry (1990s); and a variety of utility rate cases (2000s). Over the past 40 years, I have reviewed and responded to hundreds of “Expert Reports” like “The Wind Turbine Health Impact Study.”’
Download original document: “The Wind Turbine Health Impact Study Is Junk Science”
Questions arising from the Auditor General’s 2011 Report on Renewable Energy Initiatives
Source: Stelling, Keith
Summary:
With comprehensive and detailed evidence gathered independently from inside the Ministry of Energy– much of it previously unavailable to the public– the Auditor General’s Report unambiguously challenges both the rationale and implementation of the Green Energy Act.
The Act has been promoted as a mechanism for cutting greenhouse gas emissions, increasing job opportunities, and creating a competitive business environment. However the Auditor General’s investigators found little evidence that these objectives have been or would be realized. Instead it suggests that the escalating electricity costs resulting from the addition of solar and wind power to the grid with their extravagant feed-in-tariffs are having the opposite effect.
The report emphasizes “that wind and solar renewable power will add significant additional costs to ratepayers’ electricity bills”. (p.89) However there will be additional costs because “wind and solar are not as reliable and require backup from alternative energy-supply methods such as gas-fired generation”. (p.89) Nevertheless, the public was led to believe increased costs would be minimal (1%). Surveys indicated that people were willing to pay only up to 5% more for renewable electricity.
The report indicates that the escalating increase of electricity prices will continue to gain momentum as rising costs for backup, connection of renewable energy projects, spilling hydro and nuclear, and payments to renewable energy producers not to produce electricity increase. The negative implications of increased electricity costs on employment and the economy in general further challenge the practicality of the Green Energy Act. The Auditor questions whether the estimate of the number of jobs that the government claims have been created by the Act is accurate and asks why those that are being lost are not being accounted for.
However the report goes beyond assessing the financial liability of imprudent expenses and overly generous feed-in-tariffs offered to energy producers. “No comprehensive business- case evaluation was done to objectively evaluate the impacts of the billion-dollar commitment. Such an evaluation would typically include assessing the prospective economic and environmental effects of such a massive investment in renewable energy on future electricity prices, direct and indirect job creation or losses, greenhouse gas emissions, and other variables”. (p.89) Alarmingly, decisions continue to be made piecemeal without overall cost and effectiveness evaluation. The investigators found that “the ministry’s internal audit service team … had not recently conducted any audit work on renewable energy initiatives”. (p.88)
The government’s adamant contention that there are no adverse health effects from industrial wind turbines is also questioned by the Auditor General who notes that the report by Ontario’s Chief Medical Officer of Health “was questioned by environmental groups, physicians, engineers, and other professionals, who noted that it was merely a literature review that presented no original research and did not reflect the situation in Ontario”. (p.119-120)
Even more worrying, is the lack of appropriate oversight and transparency. Decisions have been made by ministerial directive and directions, relying largely on the opinion of a single inexperienced minister, while circumventing both the recommendations regarding feasibility by expert energy professionals in the Ontario Power Authority (OPA) and frustrating the responsibility for oversight by the Ontario Energy Board (OEB) to ensure that renewable energy resources are obtained in a cost-effective manner.
Detailed findings of the Auditor General’s investigations
1 Wind and solar will add significant additional costs to electricity bills
2 The government claim of 1% rise in electricity costs for renewable energy was inaccurate
3 $169 million in 2010 and $296 million in 2011 would need to be recovered from electricity ratepayers for the cost of connecting renewable energy
4 Ontario consumers were not informed of true costs of green energy
5 The government was warned in 2007 that new wind power would create higher Green House Gas (GHG) emissions
6 Minister added $44 billion to FIT contract payments against OPA advice
7 Was the Samsung agreement made without economic or business case analysis and neither OEB nor OPA was consulted?
8 Normal due diligence process not followed; no formal Cabinet approval
9 Electricity ratepayers may have to pay $150 to $225 million a year to renewable energy generators not to produce electricity
10 Backup: Consumers have to pay twice for intermittent renewable energy
11 Cost and environmental impact of backup not analyzed
12 The extent of the backup requirement has been underestimated
13 Closing coal plants will require an increase of 5,000 MW of gas-fired generation
14 Minister suspended independent assessment that would ensure decisions were economically prudent and cost-effective
15 Billions committed to renewable energy without evaluating impact
16 Despite anticipated surpluses, renewable energy generators will get paid even though Ontario does not need their electricity
Loss of oversight and transparency in decision making
17 Ministerial directives bypassing OPA and OEB lead to loss of transparency, economic prudence and cost effectiveness
18 Many directions related to the procurement and pricing of renewable energy have been issued since 2008 in the absence of an approved IPSP, and the OEB has had no oversight role
19 There has been a lack of independent oversight on the reasonableness of FIT prices
20 If the IESO instructs wind generators to shut down under a surplus-power situation, the generators still get paid
21 There has been inadequate assessment of the potential costs of curtailing renewable energy
22 Adding more renewable energy would result in curtailment cost of paying renewable generators for not producing electricity from $150 million to $225 million a year
23 The lack of correlation between electricity demand and intermittent renewable energy has created operational challenges, including power surpluses and the need for backup power
24 Surplus base load generation caused by renewable energy will add more costs for electricity ratepayers
25 In 2010, 86% of wind power was produced on days when Ontario was already in a net export position
26 Export customers paid only about 3¢/kWh to 4¢/kWh for Ontario power; electricity ratepayers of Ontario paid more than 8¢/kWh for this power to be generated
27 From 2005 to the end of our audit in 2011, Ontario received $18 billion less for its electricity exports than what it actually cost electricity ratepayers of Ontario
28 The IESO requested that nuclear generators shut down or reduce electricity supply 205 times in 2009 and 13 times in 2010
29 Recommendation 5: Assess the operational challenges and the feasibility of adding more intermittent renewable energy into the system
Socio-economic Impacts
30 Promised “green” jobs have not been produced and existing jobs may be lost because of higher electricity prices
31 A majority of the jobs will be temporary
32 Analysis should consider both job-creation and job-loss impacts, and experiences of other jurisdictions with similar renewable energy initiatives
Environmental Concerns
33 Estimated reduction in greenhouse gases did not take into account the continuing need to run fossil-fuel backup
Health Concerns
34 CMOH report questioned
35 Academic research chair has produced no report
36 Ministry of Energy should measure impact of backup facilities and provide objective research on potential health effects of wind power
