Resource Documents: Regulations (242 items)
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: Deever, Donald
As a public commentator on this highly disturbing environmental issue, I willingly preface these submitted comments by stating that my personal information should be included in this document for public view. Moreover, it is necessary to state up front that I am strongly opposed to this misguided and destructive project and that I will not cease to play a lawful part in preventing one of the country’s greatest ecological tragedies from occurring. Moreover, I share the objections of every like-minded individual and environmental organization who recognizes the priceless ecological, recreational, historical, cultural, and scenic value of the Wee Thump Joshua Tree and South McCullough wilderness areas, Castle Mountain National Monument, and Mojave National Preserve areas that will be drastically and irrevocably devastated if the proposed industrial wind turbine project by Crescent Peak Renewables is unlawfully allowed to take place in the form of hundreds of industrial wind turbine towers that will stand 400 to 700 feet high.
The subsections below concisely summarize the grounds for my opposition based on harm to biological resources, visual resources, cultural resources, tribal interests, recreational potentials, and human health. It should be noted that these objections stem from far more than personal opinion but represent scholarly research consisting of more than 1,000 pages of online documents on the topic. It should also be noted that while each of the 50 numbered passages in this public comment submission represents an objection to the aforementioned industrial wind turbine project, these numerous objections do not represent the entirety of my objections, which grow with each day that I conduct further research into this highly disturbing plan.
I. Objections Based on the Potential Harms to Irreplaceable Biological Resources
VULNERABILITY OF A VERY SMALL WILDERNESS AREA
AUDUBON IMPORTANT BIRDING AREA
RARE NESTING CAVITIES
DANGEROUS INCREASE IN PREDATORS
DECIMATION OF HERBIVORE POPULATIONS
FEDERAL, STATE, & COUNTY PROTECTED SPECIES
THOUSANDS OF COURT CASES
FEDERALLY-PROTECTED ANIMALS OF SPECIAL INTEREST
COMPLETE REVERSAL OF ROAD POLICIES
GROUND DISTURBING ACTIVITIES
BYE BYE FEDERALLY PROTECTED GILA MONSTER POPULATIONS
WHERE HAVE ALL THE BIRDLIFE GONE?
FRAUDULENT GOLDEN EAGLE DENSITY SURVEY
VIOLATION OF THE TORTOISE RECOVERY PLAN
POLLUTION OF CRITICAL SPRINGS
GOODBYE TO SOLITUDE DEPENDENT SPECIES
LOW FREQUENCY SOUND DAMAGE
BLM DOUBLE-STANDARD ON NOISE DEGRADATION
II. Objections Based on the Potential Harms to Visual Resources
UNFOUNDED ATTEMPT TO REDUCE VISUAL RESOURCE STATUS
SEQUOIA NATIONAL PARK OF JOSHUA TREES
STUNNING BEAUTY COMMENTS THROUGH THE EYES OF THE WORLD
III. Objections Based on the Potential Harms to Cultural Resources
NO PROPER CULTURAL INVENTORY TAKEN
HISTORIC WAGON TRAIL
IV. Objections Based on the Potential Harms to Tribal Interests
SACRED TRIBAL VALUE
GOOD BYE DARK NIGHT SKIES
V. Objections Based on the Potential Harms to Recreation
WORLDWIDE RECREATIONAL INTEREST COULD BE LOST
VIOLATION OF WILDERNESS MANAGEMENT OBJECTIVES
INDUSTRIAL WIND TURBINE FIRE HAZARDS
SOUTH MCCULLOUGH WILDERNESS RECREATIONAL OPPORTUNITIES
SOLITUDE & WELL-BEING DO NOT COINCIDE WITH TURBINES
PRIVATE RECOGNITION OF RECREATIONAL OPPORTUNITIES
IRREPLACEABLE VALUE OF SOLITUDE
VI. Concluding Remarks, Concerns, and Objections
CONTRADICTING EVERYTHING AN EIS STANDS FOR
VIOLATION OF NATIONAL WILDERNESS MANAGEMENT GOALS
GOING BACK ON THE PROMISE TO PROTECT SURROUNDING LANDS
TAKING THE WILDERNESS QUALIFICATION OUT OF THE WILDERNESS
THEFT OF AN ENDURING RESOURCE OF WILDERNESS
BREACH OF PROMISE / BETRAYAL OF PUBLIC TRUST
COMMERCIAL ENTERPRISES ARE PROHIBITED
DEFIANCE OF A PRESIDENTIAL AND CONGRESSIONAL ACT
NEVADA’S FIRST WILDERNESS
MORE THAN JUST THE SPIRIT OF SOUTHERN NEVADA
LOOMING GREATEST HUMAN HEALTH HAZARD OF ALL TIME [asbestos]
WHAT SHOULD BE DONE?
Download original document: “50 Reasons for Opposing the Crescent Peak Wind Project”
Author: Laurie, Sarah
Requested by Stockyard Hill Landscape Guardians –
I have used my previous clinical experience as a rural General Practitioner to interview individuals reporting adverse health effects from a range of industrial noise sources, and then used the information obtained together with my clinical insights and experience, to collaborate with trained health and acoustics professionals in Australia and internationally to plan and implement new multidisciplinary research methodologies and develop new acoustic instrumentation, to facilitate accurate measurement and recording of acoustic exposures, and concurrent physiological data (sleep and heart rate), where people are reporting adverse impacts with exposure to industrial noise sources.
The aim of this work is to identify the precise acoustic triggers for the reported symptoms, including particularly the triggering of the acoustic startle reflex that underpins much of the reported illness, especially when the acoustic startle reflex is repeatedly triggered during sleep, resulting in chronic sleep deprivation which worsens with progressive low frequency noise sensitization.
The acoustic exposures have been in residential as well as occupational settings, at open cut and underground coal mines, coal, gas and wind power generators, and other noise sources such as CSG field compressors and urban data storage centres.
International collaboration has occurred with experts such as Dr Paul Schomer, immediate past Director of Acoustical Standards in the USA. At Dr Schomer’s invitation, I was asked to join the international working group on Wind Turbine Noise in May 2015 in Pittsburgh, USA, and to present at the American Society of Acoustics conference [http://waubrafoundation.org.au/resources/acoustical-society-america-conference-2015-waubra-foundationpresentation- notes/]. I work closely with independent Acousticians, Psychoacousticians and others both in Australia and internationally who are leading the world in investigation of industrial noise inside impacted residents homes, together with the collection of concurrent physiological data.
I have collaborated with others in the development of affordable dual channel broad spectrum acoustic soundscape recording units, in order to capture scientifically important data which is being missed if averaging and sampling techniques are used, or if infrasound and low frequency noise inside and outside homes is excluded from measurement and analysis as is the case with many existing sound level meters and regulatory requirements and standards. …
I note that experienced Danish Professor of Acoustics Henrik Møller and his colleague Christian Pedersen coauthored a peer reviewed paper published in May 2011 which demonstrated (using wind industry data) that as power generation capacity increased (which can be achieved via increased tower height and blade length), so too did the proportion of low frequency noise emitted also increase. They noted that therefore it was predictable that “annoyance” for the neighbours would also increase. [https://www.wind-watch.org/documents/low-frequency-noise-from-large-wind-turbines-2/]
This increase in “annoyance” including sleep disturbance is precisely what has happened to rural residents in Victoria living near the Macarthur Wind Power Development, documented in a preliminary Community Noise Impact Survey at Macarthur Wind Power Development in 2013 by Mrs Anne Schafer, and also in numerous public submissions and oral Testimony to Federal Senate Inquiries and legal proceedings. …
The acoustic startle reflex is epitomized by the description given by residents living near various sources of industrial noise, including particularly wind turbines, of “waking up at night suddenly in an anxious frightened panicked state”. These episodes correlate directly with wind direction and weather conditions, with the worst experiences being when they are downwind, with either heavy cloud cover or temperature inversion conditions.
The acoustic startle reflex is a simple neural reflex, which is extremely rapid. The neural pathway does not travel to the cortex or thinking part of the brain, but rather goes from the peripheral sensory receptors directly to the primitive part of the brain in the brainstem, and then straight to the heart where one of the effects of the sympathetic nervous system activation is to increase heart rate. In layman’s terms, this is known as the “fight flight” response, and is the core of the physiological stress response.
By its very nature (simple and very rapid neural reflex), the acoustic startle reflex cannot be induced by “suggestion” so the assertion by wind industry advocates and some acousticians that a “nocebo” effect is responsible for the annoyance/physiological stress reactions or sleep disturbance episodes is not supported by the scientific evidence in animal studies.
Nor is the “nocebo effect” excuse supported by detailed clinical history taking directly from noise affected people by experienced medical practitioners. When such medical histories are gathered, clinical diagnoses of Environmental Sleep Disorder and other conditions including Wind Turbine Syndrome become clear, as do the serious adverse health consequences of the diagnosis of Environmental Sleep Disorder if the excessive noise exposure and sleep deprivation continue.
The effects of chronic sleep deprivation have been summarized in the 2009 World Health Organisation’s Night Noise Guidelines for Europe [https://www.wind-watch.org/documents/night-noise-guidelines-for-europe/], and include serious physical and mental health consequences. …
Two important Victorian wind turbine noise investigations since 2010 are the acoustic and health study conducted by Dr Bob Thorne at the Waubra and Cape Bridgewater Wind Power Developments [http://waubrafoundation.org.au/resources/thorne-r-victorian-wind-farm-review-updated-june-2014/], and the Pacific Hydro initiated and partly funded Cape Bridgewater Acoustic Investigation by Steven Cooper [https://www.wind-watch.org/documents/results-of-an-acoustic-testing-program-cape-bridgewater-wind-farm/]. The existence of repeated sleep disturbance was confirmed in both.
Both these wind power developments have been deemed to be compliant with their permit conditions and the NZ Standard. If they are in fact compliant, then it is clear that the NZ standard is allowing people to become chronically sleep deprived, and progressively sensitized to low frequency noise, both of which have serious adverse health sequelae for both physical and mental health.
Those who find the noise becomes unbearable, (as stated in the Victorian Health Department Technical report quoted from earlier), can become a serious suicide risk. The Waubra Foundation Administrator and Directors have direct experience and knowledge of the desperation of low frequency noise sensitized people, and I have personally prevented a number of suicides by responding rapidly, and locating local health providers in a timely fashion. My own experiences are supported by the data contained in Dr Bob Thorne’s study report referred to above, and by independent psychological assessment in some instances – these people are very unwell, physically and often mentally, and exhausted. Their psychological distress is further compounded by the lack of any action to alleviate their situation by responsible authorities at every level of government, and sometimes ignorance of their treating health professionals. …
30th January, 2017
Download original document: “Expert Witness Statement of Sarah Laurie, CEO, Waubra Foundation”
Author: Rosenquist, Kristi
A Report for the Legislative Energy Commission, 10/19/2017 —
Many Minnesotans report sleep deprivation, migraine headache, vertigo and ringing in the ears after large wind turbines are installed near their homes. Some have left their homes.
MN Department of Health identified low-frequency noise as the most likely cause and confirms that the health of some Minnesotans is being harmed by wind turbines.
Setback distance between a turbine and a home is based on wind turbine noise. State agencies concur that they understand so little about wind turbine noise they cannot even enter into rulemaking on wind turbine noise.
Minnesotans who are harmed have no recourse.
European countries more experienced with wind turbines than Minnesota have setbacks that are 10 times the height of the turbine to the blade tip at its highest point (5000 feet for large modern wind turbines).
- Site permit setback distance from homes is based on “noise” even though the State knows so little about turbine noise they cannot enter into rulemaking on the topic.
- Minnesotans’ homes are inside the turbine Safety Evacuation Zone.
- What studies does the PUC have in front of it and how did they respond?
- Citizens whose health and peaceful enjoyment of their private property are harmed by wind turbines have no recourse.
- PUC approved research of LFN by the University of Minnesota that fails to study LFN in homes and the health of people living next to turbines.
- Audible Noise – agreement that 40 dB(A) should be the limit, but no good measurement protocol to determine if it is met.
- Low-Frequency Noise is the problem. Measurable – but no standards.
- What should the Minnesota Legislature adopt for a siting standard?
- Appendix: Partial list of wind turbine LFN and health studies in PUC Docket 09-845
Download original document: “Wind Turbine Siting in Minnesota: A Report for the Legislative Energy Commission”
Download presentation (view below): “Presentation to the Legislative Energy Commission, October 19, 2017”
Author: Bronzaft, Arline
In her chapter “Sources of Noise” in Noise and Health [New York Academy of Medicine, 1991], Annette Zaner writes that sounds have been environmental pollutants for thousands of years, citing examples of stories of loud music in the Old Testament and noisy delivery wagons in ancient times. The Industrial Revolution and urbanization in more recent times raised the decibel levels in our communities, especially with the growth in transportation on the roads, on the rails and in the air, as well as the growth of noise polluting products. The proliferation of boom cars, cell phones and wind turbines during the past twenty years has made our world even noisier. Studies have been carried out that have demonstrated the potential impact of these noises on our mental and physical health, and there have been some efforts to lessen some of the intrusive sounds, e.g. aircraft and road traffic noise, but there is still too little attention paid to the deleterious effects of noise. While noise complaints top the list of complaints in major cities worldwide and noise even threatens the natural sound systems of our planet, there is no movement globally to address the noise pollutant. The following paper will examine the research linking noise to health effects, question why governments have not seriously attempted to lower noise levels and suggest ways to lessen the din. Doing so will not only be beneficial to our health and well-being but it would also be wise economically.
Arline L. Bronzaft
Professor Emerita, City University of New York
Open Journal of Social Sciences 2017; 5: 108-120.
Download original document: “Impact of noise on health: The divide between policy and science”
[T]he literature supporting the adverse effects of noise on mental and physical health has grown in the last fifteen years, underscoring the need to move ahead with federal noise legislation. …
When Dr. Nina Pierpont wrote her book reporting her findings of vertigo, dizziness, sleep disturbance and other physiological disturbances in a group of 38 residents living near wind turbines, she was widely criticized for a very limited, less than scientific study [Wind Turbine Syndrome, K-Selected Books, 2009]. Dr. Pierpont’s study calls for replication but it should not have been dismissed. In science we start with exploratory research on small numbers and then we move on to studies with larger numbers and greater control of the variables. For example, in the New York Times article on December 15th 2016, entitled “Your Brain Versus ‘Harold’,” the author reports on a study relating fitness to thinking in older people that had been conducted on sixty older men. The article indicates that further research is needed but still gives credence to the results reported. One obvious shortcoming of the study is that it only included male subjects but the author of this article in the introductory paragraph generalizes the findings to all “older people.” The New York Times in its Tuesday Science section frequently reports findings of studies with small numbers and less than ideal control as does the mass media. The findings of these studies are suggestive, although treated more seriously in the media, and should lead to further research. Dr. Pierpont’s study also should be a call for additional research exploring the relationship between wind turbine sounds and visual effects and health impacts.
In chapter 5 of Why Noise Matters there is a discussion of several studies that have found that people get more annoyed by wind turbines than noise from road traffic and other industrial sounds. Why Noise Matters concludes that noise need not stop the development of onshore wind turbines, especially if carefully located, but unless the noise issue is seriously addressed, it will harm people and curb the development. Garret Keiser in his book The Unwanted Sound of Everything [Public Affairs, 2010] states that the “noise effects of wind turbines have been routinely denied by ignorant or unscrupulous developers,” supporting his conclusion with studies affirming this statement as well as his experiences personally visiting residents in Maine who described to him the impacts that nearby wind turbines had on their lives.