Resource Documents — latest additions
Documents presented here are not the product of nor are they necessarily endorsed by National Wind Watch. These resource documents are 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.
Author: Palmer, William
Introduction. A common regulatory acceptance criterion for wind turbine installation in Canada is that sound pressure level does not exceed 40 dBA outside a home when the wind speed at 10 metres elevation does not exceed 4 metres per second. A clue to the ineffectiveness of this criterion can be seen from over 2700 complaints filed in Ontario with regulators by residents living in homes where acoustic conditions were predicted in approved models to comply with the current criterion. Residents noted the intrusiveness of an imposed sound higher in amplitude and different in quality than the pre-existing background. Residents reported disrupted sleep, and adverse health consequences. Fundamental premises of Environmental Protection Acts (EPA) are that emissions of a contaminant such as noise should not cause an adverse effect including loss of enjoyment of normal use of property, or annoyance that lead to human health impacts. …
Discussion. The subject of amplitude modulation of wind turbine noise emissions (otherwise described as a cyclical noise rising and falling in magnitude) has been a principal focus of wind turbine noise international conferences in Glasgow (2015) and Denver (2013). Monitoring of the sound inside homes displays a different character than outside, showing pulses with peak to trough amplitudes exceeding 5 dB at frequencies that are within the audible range. A simple example shows that dBA weighting does not adequately reflect perception and annoyance. White noise at 40dBA has a very different perception than pink noise at 40 dBA.
William K.G. Palmer, TRI-LEA-EM, Paisley, Ontario
Canadian Acoustics – Acoustique canadienne Vol. 44 No. 3 (2016) – pp. 42-43
Wind Turbine Noise and Human Health: A Four-Decade History of Evidence that Wind Turbines Pose Risks
Author: Punch, Jerry; and James, Richard
The primary aims of the linked article are to provide our reference sources for much of the information in that earlier series [background, evidence, and how the ear and brain process infrasound], as well as to update that information. We do so by addressing 12 specific position statements frequently made by the wind industry, its trade associations, and other surrogates. We address these position statements, many of which are revealed to be little more than unfounded talking points, by a comprehensive review of the literature, including that from industry proponents and from those who are independent of the industry.
This article is the culmination of about 15 years of our combined experience with wind turbine noise issues. We first submitted an article resembling the current one to an international journal, Noise & Health, where it received multiple reviews by a single reviewer. We addressed all but two of that reviewer’s criticisms, namely that the manuscript was too lengthy for publication in the journal and the reviewer’s insistence that we accept the notion that infrasound at levels produced by wind turbines cannot cause adverse health effects. Underlying that reviewer’s position was the belief that “What you can’t hear, you can’t feel.”
In fact, decades of research have shown that the dynamically amplitude-modulated short bursts of energy, or pressure pulsations, are a characteristic of all modern industrial wind turbine emissions. These pressure peaks can be perceived by humans at levels far below the commonly accepted thresholds of perception and can lead to adverse symptoms such as sleep disturbance, headaches, tinnitus, ear pain, vertigo, and nausea.
The editor of Noise & Health offered an additional review cycle by a second reviewer. We chose instead to withdraw the manuscript from consideration because we were unwilling to either shorten it considerably or to mischaracterize the literature on the subject at hand.
We are grateful to Hearing Health & Technology Matters for allowing us to share this information through its widely accessible website.
This paper has been reviewed both by the anonymous Noise & Health reviewer and by three other reviewers who have substantial professional experience in the area of wind turbine noise. We gratefully acknowledge the helpful contributions of Keith Johnson, Esq., Michael Nissenbaum, MD, and Daniel Shepherd, PhD.
Mr. Johnson provided a review from the perspective of an attorney who represents interveners in wind turbine siting cases. Dr. Nissenbaum provided a review from the perspective of a medical professional and expert in how ionizing and non-ionizing radiation affects humans. Dr. Shepherd provided a review from the perspective of a psychoacoustician with experience in how wind turbine sound affects people. Each of these reviewers’ comments on earlier versions of our manuscript led to the final document. The opinions or assertions contained herein, however, are the personal views of the authors and are not to be construed as reflecting the views of Michigan State University or Central Michigan University.
The article’s unusual length stems not only from the number of topics covered, but also from our desire to quote literally and liberally from researchers and others on matters related to some of the key points in support of the link between wind turbine noise and adverse health effects. Given the length, interested readers will likely require multiple sessions to read the article in its entirety.
Even though wind turbine noise does not normally cause hearing loss, we believe that audiologists, particularly those interested in community noise, should embrace the notion that all forms of noise, if sufficiently intense and prolonged, can be detrimental to public health. Audiologists should also be sensitive to the non-auditory aspects of acoustic energy, including dynamically modulated infrasound and low-frequency sound.
It is worth noting that two of the seven co-authors of the original white-paper report of the American Wind Energy Association (AWEA) and the Canadian Wind Energy Association (CanWEA), which promoted the idea that wind turbines were harmless, were audiologists. We believe that the basic conclusions of that paper, which was not peer reviewed and written by a panel hand-picked by wind industry trade associations, unjustifiably favored the wind industry. It is particularly noteworthy that those major wind industry associations have acknowledged the audiology profession as having a credible say on the issue of wind turbine noise.
Interestingly, now that the tide is turning against the wind industry in many ways and in many places, its advocates are trying to discredit the views of audiologists, physicians, acousticians, and others who speak out in opposition of wind-energy development in populated areas. Concerned audiologists, especially those with expertise in cochlear and vestibular responses to noise and vibration, need to be heard on this issue.
Finally, let it not be said that either of us believes in making any less than the best possible effort to develop clean and efficient sources of energy. Rather, we hope that our article will be instrumental in promoting public health through a better understanding of the issues underlying the potentially harmful effects of audible and inaudible noise from industrial wind turbines when the turbines are sited too close to where people live and work.
Jerry Punch, Professor Emeritus, Department of Communicative Sciences and Disorders, Michigan State
University, East Lansing
Richard James, E-Coustic Solutions; and Adjunct Professor, Department of Communication Disorders,
Central Michigan University, Mt. Pleasant
Many expert-review panels and some individual authors, in the U.S. and internationally, have taken the position that there is little literature to support concerns about adverse health effects (AHEs) from noise emitted by industrial wind turbines (IWTs). In this review, we systematically examine the literature that bears on some of the particular claims that are commonly made in support of the view that a causal link is non-existent. Investigation of the veracity of those claims requires that multiple topics be addressed, and the following specific topics were targeted for this review: (1) emissions of infrasound and low-frequency noise (ILFN) by IWTs, (2) the perception of ILFN by humans, (3) the evidentiary bases for establishing a causative link between IWTs and AHEs, as well as the physiological bases for such a link, (4) recommended setback distances and permissible noise levels, (5) the relationship between annoyance and health, (6) alternative causes of the reported health problems, (7) recommended methods for measuring infrasound, (8) foundations for establishing a medical diagnosis of AHEs due to IWTs, (9) research designs useful in establishing causation, (10) the role of psychological expectations as an explanation for the reported adverse effects, (11) the prevalence of AHEs in individuals exposed to IWTs, and (12) the scope and quality of literature addressing the link between IWT noise and AHEs. The reviewed evidence overwhelmingly supports the notion that acoustic emissions from IWTs is a leading cause of AHEs in a substantial segment of the population.
Author: Independent Noise Working Group
Initial Findings from the INWG Research
- Excessive Amplitude Modulation (EAM) is a Significant Factor. Noise complaints from wind farms are primarily related to a phenomenon called Amplitude Modulation (AM). This is commonly described as a ‘whoomp’, ‘swish’ or ‘beating’ type noise. It is the character of the noise that tends to make AM wind farm noise most intrusive. A recent Scottish study found that at 1-2km from the wind farm, 72% of those suffering audible noise strongly disliked the noise. When it becomes intrusive to people we call it EAM, or Excessive Amplitude Modulation. These noise components are not covered by the ETSU guidelines and we know of only one wind farm planning decision in the UK where a planning condition has been imposed for AM noise (Den Brook, Devon).
- There Have Been Decades of Deception. The wind industry has consistently denied the existence of EAM. Our research shows show that EAM is a frequent occurrence potentially affecting all industrial wind turbines, often for long periods of time and most frequently during the night time. A 2014 survey of Local Planning Authorities (LPAs), completed by Chris Heaton-Harris MP (Conservative, Daventry) and analysed by the INWG, shows that not only are incidents of EAM more frequent than the wind industry hitherto has claimed, the progress in resolving them is inconclusive and there are inconsistent approaches to dealing with it across the country. LPAs in the survey call for guidance on measuring and testing for EAM as well as nationally agreed standards that are consistently applied and provide effective mitigations for it. There is also anecdotal evidence of a ‘silent majority’ who suffer in silence without knowing how to complain, not wanting to get ‘involved’ or because of a fear of adverse implications; if, for example, they had to disclose any complaint should they wish to sell their house.
- Existing Legal Remedies are Found Wanting. We have found that the remedies available for wind farm neighbours affected by turbine noise are not fit for purpose. Statutory Nuisance has been actively advocated by the wind industry and supported by Planning Inspectors. Evidence however suggests that an Abatement Notice is not an effective control to protect nearby residents from EAM. Others such as private nuisance and similar legal actions have been considered but these place too much risk and burden on residents for a problem not of their making with likely long term adverse financial implications. In addition, there has been a recent trend of secondary operators forming individual shell companies for each wind farm. The impact of this was highlighted in July 2015 when David Davis MP (Conservative, Haltemprice and Howden) introduced a Bill in Parliament with the purpose of requiring wind farm developers to obtain public liability insurance for any nuisance that they may cause to nearby residents. In particular this is aimed at noise nuisance. One of his constituents had a problem with noise from a local wind farm but had found it impossible to sue because the wind farm operator was purely a shell company with very limited assets.
- Wind Turbine Noise Adversely Affects Sleep and Health. It is abundantly clear from the evidence examined by a world renowned expert in sleep medicine working with the INWG that wind turbine noise adversely affects sleep and health at the setback distances and noise levels permitted by ETSU. There is no reliable evidence that wind turbines are safe at these distances and noise levels, not a single study. In contrast there is an increasing volume of studies and evidence outlined to the contrary. There is particular concern for the health of children exposed to excessive wind turbine noise. The inadequate consideration of EAM is a major factor in the failure of ETSU to protect the human population. The denial of this by the wind industry is reminiscent of other health issues in the past. For example, the tobacco industry and the adverse effects of cigarette smoking.
- ETSU is Not Fit for Purpose. We show irrefutable evidence to discredit wind industry and government claims that ETSU provides a robust noise assessment methodology. This conclusion is supported by the recent Northern Ireland Assembly report, January 2015, into wind energy where it recommends, “Review the use of the ETSU-97 guidelines on an urgent basis with a view to adopting more modern and robust guidance for measurement of wind turbine noise, with particular reference to current guidelines from the World Health Organisation”.
- We Need an Effective Planning Condition for AM. The wind industry claims that an AM planning condition is not necessary and that the legal remedy of Statutory Nuisance provides adequate protection are thoroughly discredited by the evidence we have published. Without an AM planning condition there is no effective remedy for wind farm neighbours against excess noise. The relevance of EAM in causing noise complaints has driven the wind industry to ensure that an AM planning condition is not applied as standard planning practice. The application of an AM planning condition to the Den Brook (Devon) wind farm planning consent during 2009 presented a serious risk to the wind industry of a similar planning condition becoming the standard for future wind farm consents. The wind farm developer for the Den Brook wind farm has gone to enormous effort, at enormous expense, over an 8 year period to ensure first that an AM planning condition is not applied, then to have the applied planning condition removed, and finally to have it sufficiently weakened presumably to ensure it prioritises operation of the wind farm rather than provide the intended protection against EAM.
- There is a Lack of True Independence. The wind industry strategy of obfuscation capitalising on the trusted position of the Institute of Acoustics (IoA) as a scientific institution is discussed in our research findings. We find that the IoA through its wind turbine Noise Working Group, and latterly its specialist subgroup the AM Working Group devoted to the study of excess amplitude modulation, have consistently operated for the benefit of the onshore wind industry in the UK and to the detriment of local communities hosting wind turbines. This is also arguably against both the IoA Code of Ethics and that of the Engineering Council, its governing body. The effect has been to both obfuscate and hide problems related to wind turbine noise assessment from government and from the Planning Inspectorate.
INWG Recommendations to National Government
- Replace ETSU. Replace the use of ETSU, as recommended by the Northern Ireland Assembly report January 2015, with a procedure based on the principles of BS4142: 2014. This will bring wind turbine noise assessment into line with other industrial noise controls. New guidance of this type should be formulated in a Code of Practice that sets out a BS4142: 2014 type methodology that reflects noise character and relates impact to the actual background noise level and not an artificial average.
- Introduce an Effective AM Planning Condition. Based on the experience at Cotton Farm wind farm in Cambridgeshire, where there has been long term professional and independent noise monitoring, we recommend an effective AM planning condition should be part of every wind turbine planning approval unless there is clear evidence it is not needed. For assessing and controlling wind turbine noise AM, it is recommended that:
- Where wind turbine noise level and character require simultaneous assessment then BS4142:2014 should be used. The rated wind farm noise level should not exceed +10dB above the background noise level.
- Where only wind turbine noise AM requires assessment then a Den Brook type planning condition should be used.
- Continuous Noise Monitoring. Continuous noise monitoring of wind turbines should become a standard planning condition for all wind turbine planning approvals as recommended in the Northern Ireland Assembly report, January 2015. This should be funded by the wind turbine operator but controlled by the Local planning Authority (LPA) with the noise data made openly available to ensure transparency. The Cotton Farm community noise monitor describes an example of how this can be achieved. See: http://www.masenv.co.uk/~remote_data/
- Further Research into the Impact of Low Frequency Noise. There is a need to commission independent research to measure and determine the impact of low-frequency noise on those residents living in close proximity to individual turbines and wind farms as recommended in the Northern Ireland Assembly report, January 2015.
- Issues of Ethics, Conflict of Interest & Independence. The government should deal decisively with the ethical issues surrounding the Institute of Acoustics (IoA) wind turbine noise working groups. Government departments should disassociate themselves from the IoA until conflict of interest and ethics issues are resolved and full transparency is restored.
Download reports and publications:
The Fundamentals of Amplitude Modulation (AM) of Wind Turbine Noise
Review of Reference Literature
AM Evidence Review
Study of Noise and AM Complaints Received by Local Planning Authorities in England
Excessive AM, Wind Turbine Noise, Sleep and Health
Den Brook Planning Conditions
Draft AM Planning Condition, part 1
Draft AM Planning Condition, part 2
Legal Issues Relating to Shell Companies
Control of AM Noise Using Statutory Nuisance
Informative: Wind Turbine Noise AM and Its Control
Test of Institute of Acoustics AM Working Group Methodologies [not yet published]
Review of Institute of Acoustics Noise Working Groups
Cotton Farm Monitor Experience
Terms of Reference
Presentation to DECC Minister of State by Richard Cox
Presentation to DECC Minister of State by Sarah Large
Presentation to Institute of Acoustics by Richard Cox
Reply Brief of Petitioners Friends of the Columbia Gorge and Save Our Scenic Area v. Bonneville Power Administration
Author: Friends of the Columbia Gorge
To try to justify its violations of NEPA (including a failure to consider any alternatives besides the Applicant’s proposal and a failure to take a hard look at the Project’s environmental impacts), BPA leans upon the slender reed of lacking direct siting authority over the Project’s wind turbines. But the inescapable reality is that BPA evaluated the proposed wind turbines and the requested interconnection to its power grid together as components of the single action alternative in the FEIS. Moreover, BPA has conceded that if it were to deny the interconnection the turbines would not be built. Accordingly, BPA was required to comply fully with NEPA to inform its decision whether to approve or deny the interconnection.
Ultimately, BPA has authority to say “no”—to the interconnection, and thereby to the entire Project—and NEPA requires it to make an informed decision and thus potentially avoid or minimize harm to the environment. BPA’s litigation position posits an alternative reality in which the agency did not evaluate the wind turbines and interconnection together as a single action, and did not admit that the interconnection is a necessary element of the Project without which the wind turbines cannot be built. The analyses adopted in the FEIS—not the agency’s current litigation position—must be the focus of this Court’s review.
BPA’s arguments rely almost entirely on cases in which federal actions were completely distinct from non-federal actions—rather than intertwined, as the proposed wind turbines and interconnection are here—and on knocking down straw-man arguments that Friends does not make. The fact that BPA can cite no case where a court upheld an EIS that considered only a single action alternative involving several undefined variables underscores the unprecedented way BPA evaded NEPA’s express requirements.
Although BPA may “believe that the Project will be implemented in an environmentally responsible manner,” it failed to follow the procedures NEPA requires to draw an informed conclusion about likely harm from the proposed Project as compared to reasonable alternatives. BPA asks this Court to condone a NEPA analysis that in essence evaluated only a single, worst-case alternative and that lacked any evaluation whether the proposed mitigation measures could effectively reduce or eliminate harm.
Where an agency could prevent environmental harm, as BPA could do here by denying the requested interconnection, NEPA and this Court’s precedents require the agency’s decision to be fully informed and to include a complete understanding of the effects of reasonable alternatives—even alternatives not within BPA’s jurisdiction. An evaluation showing that changes to the number, locations, capacities, heights, or other details of the proposed wind turbines would cause significantly less harm to birds, bats, or scenic values might have led BPA to deny the requested interconnection. BPA’s uninformed decision violates NEPA and its procedures for ensuring informed, democratic decisionmaking.
Sept. 26, 2016, Docket No. 15-72788, United States Court of Appeals for the Ninth Circuit