Wind Energy Development Guidelines.
Targeted revision issued Dec 12 2013
General Background
With respect to residential communities, the most critical consideration of on-shore Industrial Wind Energy
development is the setback or separation distance from homes. This criticality is due to:

the potential for noise impact on residents in close proximity and its associated affects on sleep and
consequently health

the impact on the value of residents property – the affect is particularly significant within 2km.

the potential for shadow flicker on a residents home

the overall impact on the landscape and general amenity of residents
Therefore it is imperative that the combination of limits set by the Guidelines should ensure that the appropriate
set-back is achieved for each and every home in the proximate area of a proposed Industrial Wind Development.
The draft Wind Energy Development Guidelines (WEDG13), purport to strike a balance between the protection
of residential amenity and facilitating wind energy. It is evident that they will certainly facilitate wind energy
development, what is not clear is how they offer any level of protection to residential amenity.
The revised Guideline states that it “seeks to achieve a balance between the protection of residential amenity of
neighbouring communities in the vicinity of wind energy developments, and facilitate the meeting of national
renewable energy targets”. It is my view, thus far, that the balance is firmly in favour of the developments and
significantly removed from community concerns.
It is also deeply regrettable that the Department has considered it appropriate to consider only 3 aspects of the
Guidelines, while there are firm proposals in place to develop 28,000MW and beyond, of wind-derived
electricity in Ireland over coming years. This corresponds to almost 10,000 turbines (at 3MW capacity). The
current level of turbines installed in Ireland at this point in time is approximately 1000. The entire Guideline as
it currently stands, promotes irresponsible on-shore Wind development. It should, at the very least, set out up
front, in a very transparent manner, the cost-benefit analysis for wind-derived electricity; this analysis requires a
clear and honest evaluation of the net impact on Carbon emissions, as a result of wind development, taking a 15
year usage horizon into account.
As a Family that have had to live for the past 16 months with the possibility of 550 ft wind turbines being
positioned 700 metres from our home i can only let you know that live has become almost unbearable and has
led my family to decide that relocating to another country will be the best option for the whole family. We
dispair for other families in our position and have come to the conclusion that no-one listens and no-one cares.
If anyone is going to actually read this submissions then i hope that you will sleep easy at night far away from
these turbines that are a waste of money for the tax-payers of this country. Shame on you all.
The recommendations below, as underlined, must be incorporated in the final draft of the guidelines.
(A) Noise limits
(1) Measurement:
The current Guideline promotes the used of the LA90 noise indicator. This is not appropriate.
Similar to speed measurement in km/hr vs miles/hr, the same situation arises when comparing the 2 noise
indicators i.e. 120mile/hr is a lot faster than 120km/hr. With regards to noise, the WHO night noise limit is
40dB(A). It is measured using LAeq; if measured with LA90, it would 38dB(A).
LAeq. This is the noise indicator which must be used as it quantifies average sound levels experienced. This
is in line with standards accepted and implemented across the EU;
LA90. Measures the noise level which is exceeded 90% of the time i.e. it disregards the noisiest 90% of the
measurement period and is a measure of the loudest noise during 10% of the measurement period. It may be
more appropriate for measuring background noise levels as it ignores singular noise events such as a passing
car. Use of this measurement does not comply with international best practice for the assessment of new
environmental noise sources. See Marshall-Day Report pg 10 for illustrative purposes. As the human ear
does not disregard 90% of noise experienced, then this measurement indicator is considered inappropriate
for Wind Turbine noise measurement.
(2) Limit:
40dB (LAeq) or 5dB above measured background noise levels, whichever is the lower.
Background noise levels to be measured at representative neighbouring dwellings, up to 2km from proposed
turbine locations. Ignoring existing background noise levels is in breach of the EIA Directive (and the END
Directive requirement for the protection of Designated Quiet Areas), so the consideration of background
noise levels must be included in the WEDG. As the Marshall Day report highlights "a 5dB increase in sound
level can be described as clearly noticeable", so in legalese 5dB is at the upper limit of what any 'reasonable'
person could be expected to accept.
(B) Set Back Distance:
A default set back of 10 x base to tip height is required.
This recommendation is based on conclusions by many experts, such as Dr Chris Hanning1, Consultant in
Sleep Disorders, UK who discusses adverse impacts on sleep at distances of up to 2km and greater, based
on a turbine height of 125m.
It is also the conclusion of the Japanese research paper by Yano2 on Wind noise impact on residents, which
specifically assesses severity of annoyance to residents, caused by Wind Turbine noise. Approx 750
individual homes were surveyed and it is clear, based on this study, that a minimum of 1.5km separation
distance is required to minimise “severe annoyance”. Current and future (larger) turbines would require a
correspondingly greater set-back distance. A formulaic distance is therefore appropriate rather than a setpoint, hence the 10 x times-height as setback distance.
Furthermore, the Deputy Chief Medical Officer, Dr. Collette Bonner, advised Minister Jan O’Sullivan’s
department (Nov 2013), in response to a request for input to the WEDG revision process, that "there is a
consistent cluster of symptoms related to wind turbine syndrome which occurs in a number of people in the
vicinity of industrial wind turbines. There are specific risk factors for this syndrome and people with these
risk factors experience symptoms."
As a general recommendation Set-back Distance should be modelled appropriately via a thorough and
transparent model based on noise. Such a model to be conducted for the range of Irish Landscapes: flat open
farmland; cutaway bog area; hilly farmland terrain; mountain terrain; coastal terrains etc. and at a range of
wind speeds. Concerned communities of Ireland must be allowed to appoint independent acoustic experts to
verify the modelling protocol and associated outcome.
Land Development sterilisation impact: an opt-out provision can be made in the Guidelines to allow
development within the set-back zone, post construction.
References:
1
BMJ 2012; Wind turbine noise affects on Health344:e1527 doi: 10.1136/bmj.e1527 (Published 8 March
2012); Hanning & Evans.
2
Dose-response relationships for wind turbine noise in Japan - Yano, Kuwano, Kageyama, Sueoka and
Tachibana), presented at InterNoise (Noise Control for Quality of Life conference), Innsbruck, Austria,
September 2013.
(C) Shadow Flicker
1. The draft Guidelines introduces the concept of Shadow Flicker being an issue within 10 rotor
diameters of a dwelling and which should be dealt with appropriately: “A condition should be
attached to all planning permissions for wind farms to ensure that there will be no shadow flicker at any
existing dwelling or other existing affected property, within 10 rotor diameters of any wind turbine. A
further condition should be included which states that if shadow flicker does occur, then the necessary
measures, such as turbine shut down during the associated time periods, will be taken by the wind energy
developer or operator to eliminate the shadow flicker.” The language is too loose and does not put
any legal obligation on the developer to adhere to this guidance.
2. The Guideline revision does not prescribe mandatory conditions for eliminating Shadow Flicker
incidence on dwellings. Mandatory elimination is a must.
3. Given that the Noise limit for sensitive locations can be seen to have increased vs the 2006
Guidelines and set-back distance has remained the same, then it is now clear that Shadow Flicker
controls provide no further amenity protection, with respect to influencing setback distances to a
safe and responsible distance. In any case, the Shadow Flicker guidance is applicable only as a
control to those residents living on the northerly side of the east-west plane of a turbine.
Noise Definitions
LA90 10min: In technical terms, LA90 10min is the tenth percentile of the distribution of the A‐ rated sound
level measured over a ten minute period.
In non‐ technical terms, it is calculated by measuring the noise level over a ten minute period,
disregarding the noisiest 90% of the time and taking the maximum noise level in the remaining
(quietest) 10% of the time.
LAeq is the energy average of the noise over a given period.