Resource Library Category: Ontario (54 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.
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
Re: Ministry of the Environment Media Release “Expert Report Confirms No Direct Health Effects from Wind Turbines”
Source: Gillespie, Eric
We are the solicitors for Wind Concerns Ontario (“WCO”). WCO has analysed the contents of the Ministry of Environment (“MOE”) December 16, 2011 media release “Expert Report Confirms No Direct Health Effects From Wind Turbines” (the “MOE Media Release”): http://news.ontario.ca/ene/en/20ll/12/expert-report-confirms-no-direct-health-effects-from-wind-turbines.html.
The apparent purpose of the MOE Media Release is to “educate” the public on matters related to wind turbine noise exposure and human health. As part of its mandate, government is responsible for providing citizens with accurate and appropriate information so they can protect themselves and/or their health. Furthermore, the Renewable Energy Approval (“REA”) process requires full and accurate disclosure of any potential health effects of renewable energy projects. It appears the MOE Media Release does not fulfill these responsibilities.
For example the MOE Media Release contains a link to a MOE web page entitled “Backgrounder: Low Frequency Sound and Infrasound Report” (the “MOE Backgrounder”) which states:
Is wind turbine sound harmful?
The best available science shows there is no direct health risk from wind turbine noise.
An uninformed member ofthe public could incorrectly interpret this MOE Backgrounder statement to mean wind turbine sound cannot harm human health.
As you should be aware the evidence and expert testimony provided during a 2011 Ontario Environmental Review Tribunal (“ERT”) confirmed wind turbines can harm human health. The July 18, 2011 ERT Decision states:
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.
At the request of our client we are providing the following references to assist the MOE in fulfilling its responsibilities to fully and accurately describe any negative effects on health and safety. The references set out in this letter reflect generally accepted acoustical and psychoacoustic principles. The references also include ERT evidence and/or testimony provided by witnesses for the Respondents at the ERT hearing (the Ministry of Environment, Suncor Energy Services Inc.). …
ERIC K. GILLESPIE PROFESSIONAL CORPORATION
Barristers & Solicitors
January 3, 2012
TO:
The Honourable J. Bradley, Minister of the Environment
The Honourable C. Bentley, Minister of Energy
The Honourable D. Matthews, Minister of Health and Long-Term Care
Ms. Doris Dumais, Director, Approvals Program, Environmental Assessment and Approvals Branch, Ministry of the Environment
Mr. Brian Howe, MEng, MBA, PEng, Principal, Howe Gastmeier Chapnik Limited (HGC Engineering)
Response to HGC Literature Review
Source: Harrison, John
Response to “Low Frequency Noise and Infrasound Associated with Wind Turbine Generator Systems – A Literature Review”
Also see: “Compliance Protocol for Wind Turbine Noise – Guideline for Acoustic Assessment and Measurement”
Introduction
The low frequency report, prepared by Howe Gastmeier Chapnik Ltd. was commissioned by the Ministry of the Environment (MOE), released in draft form in August 2010, released in final form to MOE in December 2010 and to the public in August 2011. Why MOE is issuing it now as a press release is a mystery. This response will address the report itself and the news release from the Ministry of the Environment.
A glaring omission from the report and the news release is the motivation for the commission to HGC. The motivation of course is that a large number of residents living in proximity to wind turbines are suffering from annoyance, sleep deprivation and resulting adverse health effects. The root cause of the annoyance is the noise generated by wind turbines.
Not only does the report and news release avoid mention of the motivation for the commission, neither MOE, the Ontario Chief Medical Officer of Health nor HGC made any attempt to interview those suffering from adverse health effects
The commission focused on low frequency audible sound and infrasound because at a distance of several hundred metres from a turbine much of the high frequency sound has been absorbed by the atmosphere.
The annoyance associated with turbine noise is considerably larger than noise of a similar sound pressure level generated by traffic or industrial noise. For instance field studies by Pedersen, van den Berg, Bakker and Bouma (referenced in the report) show 15% and 27% of a population are annoyed by sound pressure levels in the ranges 35 to 40 dBA and 40 to 45 dBA respectively. [Pedersen et al. consider five reactions to turbine noise: do not notice; notice but not annoyed; slightly annoyed; rather annoyed; and very annoyed. They group rather and very annoyed together under the heading “annoyed”.] These numbers are to be compared to 3% of a population annoyed by traffic noise in the same sound pressure level range. The present Ontario noise limit is 40 dBA; the noise limit before the Green Energy Act was 51 dBA in a sufficiently high wind. As noted below the Ontario noise limit is based upon prediction with significant noise contributions to the prediction not considered.
Possible reasons for the difference in response to turbine noise and road or industrial noise is the predominance of low frequencies in the turbine noise and the characteristic amplitude modulation of turbine noise at the blade passage frequency; this amplitude modulation draws continual attention to the turbine noise in the way that a dripping tap does. The wind industry and its lobbyists make much of the contribution of attitude to wind turbines to the annoyance. However, it is difficult to think that the attitude to industrial plants or road noise would be any less benign. In addition, while Pedersen et al. show a linear dependence of annoyance on the turbine sound pressure level there is no similar study showing a linear dependence of annoyance on attitude!
Not for nothing do the following health and other experts propose setbacks well beyond those allowed by the Ontario Ministry of the Environment:
The HGC report gives considerable prominence to the Colby et al. health study and to the Chief Medical Officer of Health, Dr. Arlene King, health study. The one was commissioned by the Canadian/American Wind Energy Authorities and the other by the Ontario Government which is far from unbiased with respect to wind energy. Both are seriously flawed, notably in having no interest in the numerous people suffering from adverse health effect and in emphasizing the absence of direct health effects. Generally the adverse health effects are indirect: sleeplessness and annoyance leading to stress-related illnesses. This is recognized by the World Health Authority which considers annoyance and stress as adverse health effects. A recent paper by Dr. Carl Phillips, a noted epidemiologist, offers a detailed critique. The King report is marred by an erroneous quotation from the 2009 Pederson et al. paper of the number of people annoyed by turbine noise. Dr. King has yet to acknowledge this error/deception.
Technical Review
As must be, much of the HGC report concerns technical aspects of noise generation and sound propagation. Here there is a fairly complete literature review. However, this section fails to emphasize that the turbine manufacturers are aware that the future of widespread acceptance of wind energy will depend upon reducing noise and low-frequency noise. To quote:
“The acoustic noise radiating from wind turbines continues to be the dominant design driver that must be incorporated into the design process. The tip speed of many turbine designs is limited by the amount of noise created by the blades passing through the atmosphere.” Moriarty (NREL, USA) et al., AIAA Conference Proceedings (2005).
“… noise emission … has become one of the most important environmental impacts of wind energy.” (Romero-Sanz and Matesanz (Gamesa Spain), Wind Engineering, 32, 27-44 (2008))
As stated in the report a major cause of turbine noise is aerodynamic trailing-edge vortex creation. There has been theoretical and wind-tunnel research to investigate the effect of different blade cross-sections on TE noise.
Perhaps of far more importance for low frequency and infrasound noise is the work on inflow turbulence. HGC, the Ministry of the Environment and CanWEA continue to bury their heads in the sand concerning this issue. This important noise source has been brought to the attention of MOE and the Canadian acoustics community by bringing to light the early work at the National Renewable Energy Laboratory (NREL) in the USA. This work demonstrated through theoretical work based upon the mathematical modelling by Amiet and through experimental work with the NREL CART up-wind test turbine that turbulent inflow considerably enhances the low frequency noise emitted by turbines. More recently, Dr. Moriarty has brought to my attention their continuing work, in collaboration with Dr. Guidati, well-known as a co-author of the Wagner et al. treatise on wind turbine noise.
On July 8th, 2011, The National Laboratory for Sustainable Energy, Risø, Denmark placed the following description in an advertisement for a scholarship: “Noise is an interesting concern for wind turbine manufacturers and communities living near wind turbines. These concerns are exacerbated by the constant increase of wind turbine sizes and the cost advantages of placing turbines close to the consumers. The design of low-noise turbines requires the use of validated and accurate engineering models. The main sources of noise generated by a wind turbine have been identified as turbulent inflow noise and trailing edge noise”
If still not convinced then Figure 32 of a recent report by K.D. Madsen and T.H. Pedersen should be enough (“Low Frequency Noise from Large Wind Turbines” DELTA report AV-1272/10 (2010)).
Other work not referenced concerns measurement of turbulence intensity. This work is being done because turbulence increases dramatically low frequency noise, because it puts stress on the turbine blades and because, with associated wake loss, it decreases the capacity factor of downwind turbines. A list of references that needed to be addressed is as follows:
Lange et al., “Modeling of Offshore Wind Turbine Wakes”, Wind Energy, 6, 87 (2003).
Barthelmie et al., “Modeling and measured Power Losses and Turbulence Intensity …”, Wind Energy, 10, 517 (2007).
Wagner et al., “Influence of Wind Speed Profile on Wind Turbine Performance Measurements”, Wind Energy, 12, 348, (2009).
Barthelmie et al., “Off-Shore Wind Turbine Wakes Measured by Sodar”, J. Atmos. Oceanic Tech., 20, 466 (2003).
Bertaglio, “NACA0015 Measurements in LM Wind Tunnel and Turbulence Generated Noise”, Risø National Laboratory for Sustainable Energy (2008) (report # Risø-R-1657(EN))
In Europe, the European Commission is supporting turbine research through the SIROCCA Project: http://www.ecn.nl/nl/units/wind/projecten/sirocco/
Propagation of Low Frequency Noise (Section 3.2)
The report makes important points concerning the propagation of turbine noise: The cylindrical decrease in sound energy, the acoustically hard character of ground for low frequency sound, the low absorption by the atmosphere for low frequency sound and the ready penetration through residence walls. These points needed to be emphasized in the executive summary, the conclusions and the recommendations. At present they are not acknowledged by the Ministry of the Environment. This is especially important as guidelines are drawn up for off-shore wind energy.
Noise Annoyance (Sections 3.5, 3.6 and 3.8)
Laboratory studies have their place. Nevertheless, for reasons that Dr. Leventhall gives, as referenced in section 3.6, far more weight needs to be given to field studies in comparison to laboratory studies. Missing from Section 3.6 is consideration of the amplitude modulation. This is typically 5 dBA but higher values have been reported. Dr. Leventhall himself has written: “A time-varying sound is more annoying than a steady sound of the same average level and this is accounted for by reducing the permitted level of wind turbine noise”. As we are well aware, the Ministry of the Environment refuses to do this.
Section 3.8 quotes the work of Pawlaczyk and Luszczynska. It was only fair to have quoted also the work of Persson Waye et al. (“Low Frequency Noise “Pollution” Interferes with Performance”, Noise Health, 4, 33, (2001)). This paper comes to the opposite conclusion for low frequency noise at the 40 dBA level.
Health Effects (Section 3.11)
The Colby et al. and King reports were dealt with above. Turning to the discussion of Dr. Pierpont’s work, the report is bizarre. There is no mention of the bulk of the work on the medical study of a large number of people suffering adverse health effects resulting from wind turbine noise. This work analyses the range of symptoms and finds reason to treat them collectively as a syndrome. Separately, there are hypotheses for the cause of the syndrome. Hypotheses are not proofs; scientifically, the presentation of a hypothesis is reason to study the problem and to demonstrate proof or otherwise. Whether the hypotheses are correct or not is irrelevant to the fact that there are adverse health effects. The energy devoted by Colby et al., King, CanWEA to denigrate the medical and diagnostic work of Dr. Pierpont is reminiscent of the methods we saw some decades ago used by the tobacco industry! Again, I recommend a reading of the Phillip’s report on the power of crossover analysis in understanding the reality of adverse health effects from wind turbine noise. There is a reference to Leventhall (2010) missing from the bibliography; nevertheless, I know that Drs. Leventhall, Colby and King are not epidemiologists!
Conclusions (section 5.0)
1) Although turbine noise is broadband, at a distance of 500 metres, much of the high frequency sound has been absorbed. Distance enhances the low frequency component as does turbulent inflow.
3) Reference needs to be made to the Salt study demonstrating other pathways for the perception of very low frequency sound.
4) This conclusion is wrong and is a red herring. Turbine noise in the range 35 to 45 dBA causes annoyance and sleep disturbance. These are adverse health effects and in turn lead on to other adverse health effects. 100 people reporting adverse health effects and more than a dozen families abandoning their homes in Ontario alone gives the lie to this conclusion.
5) Non-trivial (a derogatory and unworthy expression) has no place in a professional report. It should be replaced by about 20% being annoyed.
Recommendations (Section 6)
Given that the review of current technical literature in the HGC report has missed completely research dating back to Amiet and forward to detailed comparisons between theory and experiment on turbulent inflow noise, the first recommendation needs to be revised. MOE does need to revisit its guidelines to include turbulent inflow noise, to treat the ground parameter as hard for low frequency sound, to reconsider spherical spreading, particularly for off-shore sound propagation, to address the uncertainty in the prediction of sound at a residence and, given the accepted enhancement of annoyance due to amplitude modulated noise, to apply a penalty for amplitude modulation.
Response to Backgrounder: Low Frequency Sound and Infrasound Report
What kind of noise do wind turbines produce? Turbines do indeed produce a wide range of frequencies. However, the noise 550 metres or more from the turbine is skewed towards low frequency noise because of selective absorption of the high frequencies by the atmosphere.
Is wind turbine sound harmful? The Minister of the Environment writes that there is no direct health risk. However, field studies have demonstrated that 15 to 27% of people exposed to turbine noise at the Ontario regulated limit will suffer annoyance. This is an adverse health effect and in time leads on to other adverse health effects such as stress, tinnitus, headaches and sleep disturbance.
Are Ontario’s rules to control wind turbine sound stringent enough?
The minister writes that at the Ontario regulated setback much of the sound that turbines produce lays outside the range that people can hear. This is untrue. Field studies show that at the regulated setback, 80% of people can hear the turbine noise. Also, the minister fails to note that Germany, with its more extensive experience with wind energy, has a lower night-time noise limit than Ontario.
John Harrison, harrisjp/physics.queensu.ca
