Dear Planning Minister Rau;
I was a participant in the Waterloo wind farm noise study and you would be aware from all my previous correspondence with you over more than two and a half years, that I am personally acquainted with the large number of decent and genuine people in the Waterloo district community who ARE suffering adverse sleep impacts and other health effects from this wind farm.
I feel compelled to write to you and point out that your Ministerial decisions to approve Keyneton and Ceres wind farms, superficially justified by EPA Waterloo Noise study 2013 study are ill-founded and reprehensible.
In October 2012 you in confirming the Interim wind farm DPA, you ignored key recommendations from the DPAC concerning greater setback distances, precautionary approach, cumulative impacts, safety concerns and many others.
You clearly rushed the Keyneton decision through with indecent haste, a mere 10 days after the EPA Waterloo report was released. Insufficient time for through comprehension of the complex and lengthy document and without the benefit of peer reviews by other acoustic experts.
Why did you not wait until thorough peer reviews of the EPA study and reports were forthcoming?
Why did you not wait until the results of independent researchers monitoring side by side with the EPA (Emeritus Professor Colin Hansen and Steven Cooper) were published?
Now it appears that you have repeated the rushed performance with the CERES Project on the Yorke Peninsula, just before your government goes into caretaker mode.
Can you please justify taking the conclusions of the EPA at face value without bothering to wait for independent verification?
The first PUBLICLY AVAILABLE peer review of the document has only just come to light!
My requests for a copy of the NSW EPA peer review cited by the SA EPA have been denied by the SA EPA and the NSW EPA, and seems that this is a confidential document and not available for scrutiny – Why not? What does it say about the EPA study?
And how can you justify ignoring the recently released opinion of acoustic engineers (Cooper and Hansen) with arguably the most experience of monitoring wind farm noise in the local environment at Waterloo?
Last week, after many weeks of examining the EPA report, expert acoustic engineer Emeritus Professor Colin Hansen made public his comments about the study .
Professor Hansen commented:
The EPA found “no evidence linking the noise from the wind farm to adverse impacts on residents” and there are several reasons why this conclusion may have been reached erroneously. These include certain limitations of the current guidelines as well as aspects of the study that could have been improved. In some cases, interpretation of the data has led to generalisations that are not well backed up by the supporting figures.
I do not believe that the EPA study has shown that the noise impact on residents from the Waterloo wind farm is insignificant. More detailed analysis of the data and analysis of the appropriateness of the existing EPA guidelines would in my opinion indicate a significant impact of the wind farm noise on local residents.
As a layman, I too, have spent a significant amount of time in the last couple of months scrutinising the SA EPA’s 2013 Waterloo Wind Farm Environmental Noise Report.
Being familiar with the homes and residents where EPA monitoring took place and having been given copies of the diaries submitted to the EPA, I have identified significant issues with methodology, collation of diary entries, microphone placement, inappropriate timing of shutdowns to secure meaningful results, equipment failure, missing data, failure to consider “awakenings” and sleep disturbance as an indicator of noise level, errors in tables, errors in shutdown dates (pdf version lists the last 4 shut downs as occurring in May, when they were in June). The document is large and cumbersome to follow. I am still compiling my complete list of flaws in the document, but just some of them are attached to this email.
It is obvious that you applied no scrutiny to this EPA document, because a mere 10 days after the EPA report was released, with indecent haste, you approved Keyneton wind farm on Friday 6 December 2013.
Your words from your press release and media conference included:
There is no detectable concern based on noise emanating from these proposed installations and for that reason the approval has been given.
No evidence was found linking noise from the wind farm to adverse impacts on residents.
However, the SA EPA online report contains the following disclaimer (which apparently was edited from the pdf version of the report):
The conclusions of the study may not be valid for other wind farms, and may only be valid for the Waterloo Wind Farm under the specific conditions (eg weather, wind farm operating conditions, etc) under which the study was undertaken. It also may not necessarily be valid for all residences potentially affected by noise emission from the Waterloo Wind Farm.
The SA EPA stated from the beginning of the study and repeatedly throughout, that their study was not a health study.
The Waterloo study does not and can not support claims that there are no adverse health impacts from the Waterloo wind farm as it was not a health study.
17 of the 28 households involved in the study have provided me with a copy of their noise diary as sent to the EPA over the course of the study, with a view to wider scrutiny of the SA EPA’s analysis and conclusions. This process is still a work in progress.
The SA EPA have only considered diary entries relating to audible noise in their report, and neglected other impacts – most notably – sleep disturbance and awakenings.
The consequence of this selectivity is that a large number of adverse impacts and events recorded by the residents specifying time as and dates of disturbance which could be have been compared to noise data have been ignored in the analysis and report.
For example, the following entry has been disregarded; [it] clearly indicates adverse impacts from sleep disturbance and yet the EPA has illogically come to the conclusion that there are no adverse impacts and the guidelines do not need to be reviewed.
8th–10th May Loud whining noise constantly. Had son who works as diesel mechanic 7:30am–5pm daily. Yelling out at night as the windmill noise was keeping him awake 3 nights in a row. Went to work tired
At the time of the EPA study, this family lived 7 km from the turbines, but have since (November 2013) moved to another home further away where their sleep is not disturbed.
The EPA have summarized just over 800 diary entries from the 28 households in a series of tables in the report.
This equates to an average of 80 complaints per week over the 10 week period.
Only diary entries relating to audible noise, vibration and pulsing have been summarized.
In just the 17 noise diaries I have access to, there are well over 900 combined entries (audible noise + symptoms) which pinpoint times and dates of awakenings and other events – ALL of which could have been investigated, but a significant number have not because they were “not audible”.
Consequently much useful information which relates to sleep disturbance and health effects seems to have been disregarded by the EPA.
The Waterloo and Districts community reject the EPA’s conclusion that the current guidelines are sufficient to protect the residents from adverse impacts and do not need reviewing. Standards that result in residents abandoning their homes full time or partially clearly do not afford the community adequate protection from adverse impacts, are inadequate and must be amended.
WHO Guidelines on Community Noise 1995  are clear that night time noise inside homes exceeding 30dB(A) causes sleep disturbance and extensively documented associated adverse health effects.
Yet SA wind farm noise guidelines do not include a requirement to measure inside houses in the night time. The EPA only requires measurements outside homes and all measurements over a 2 week period are effectively averaged.
It is peak pulsing noise levels that matter – not averages – especially at night time when people are trying to sleep.
The current SA noise guidelines seem to be crafted to ensure that peak levels are hidden in averages and therefore compliance is practically assured. They lag behind international best practice and do not reflect recent independent scientific both locally and in the US.
It seems that the SA wind farm PLANNING, NOISE REGULATION and COMPLIANCE processes are a farce driven by political rather than scientific impetuses.
Justice demands a thorough audit and inquiry.
I await your response with interest