Evaluation of Noise Impact Assessment (Section 11 page 60) submitted as part of the ADAS (UK) Ltd Environmental Appraisal for the Proposed wind cluster Sedborough Farm Parkham (Planning application number: 1/0242/2008/FUL)
by Mike Stigwood, FRSH, MIOA of MAS Environmental
10th May 2008
2.1 The ADAS UK report for this site contains inadequate information to reach an informed decision because a full Environmental Statement based on a properly conducted EIA has not been included with in the planning application.
2.2 I understand research undertaken in the UK by Andrew Bullmore, an acoustician working on behalf of the British Wind Energy Association, recommends turbines are situated a minimum distance of 700 metres from any dwelling (reported at a one day conference in Hartlepool July 2004). Another UK study by the Noise Association (Location, Location, Location released in July 2006) considered 1 mile an appropriate minimum separation distance, and in France the National Academy of Science recommend 1.5km. In this case dwellings are as close as 527 metres (refer to figure 11.1 of the report for the proximity of turbines to properties).
2.3 The noise element of the report is seriously defective and planning permission should not be granted on the basis of the information supplied, for the reasons set out in this report. There is serious and repeated misapplication of guidance and in particular the decision not to provide background noise data for the assessment in this case is deeply flawed and directly contrary to ETSU-R-97. Such an approach is only advised with single turbines and large distances to property. In this case dwellings are, in wind turbine terms, very close.
2.4 Serious error also arises in relation to the modelling applied to noise propagation which significantly under-estimates the noise levels. I have dealt with this in detail later. The consequence is that the assessment is unreliable. …
3.0 Why ETSU-R-97 should not be relied upon to assess noise impact from these large wind turbines.
3.1 The Noise Impact Assessment which accompanies the planning application relies on ETSU-R-97, applied slavishly to this situation. This is deeply flawed. ETSU-R-97 is a planning tool which should be used but it does not follow that it should be applied blindly to this development. ETSU-R-97 is incapable of addressing the noise impact issues created by large turbines and thus while it is important to use this tool, its guidance and advice must be modified to reflect the differences that arise. Failure to do this renders the assessment of little value.
3.2 In ETSU-R-97 impact from turbines up to a hub height of 32 metres were considered. Turbines up to 32m are generally considered as medium sized and are small compared to some of the behemoths now being constructed. There is no direct point of transition between medium and large turbines but those with hub heights of 50 metres and blade diameters also of 50 metres or more are clearly large turbines.
3.3 Paragraph 22 of Planning Policy Statement (PPS22) states you should use ETSU-R-97 but it can only be used where it is applicable or its guidance addresses the sound energy impacts likely to arise. The Companion Guide to PPS22 recognises it is not applicable in all situations. The main PPS22 is silent on its limitations and it is clear the reader must go to the Companion Guide for detailed advice. The Companion Guide also provides much more pertinent advice. …
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