Written submissions or observations with respect to the public consultation process on
proposed revisions to the 2006 Wind Energy Development Guidelines are invited, via email to
windsubmissions@environ.ie up to February 21st 2014.
To that end the following is the submission of The Garryhinch Wind Awareness Group.
General Background.
We believe that it is imperative that any review of the Guidelines examine all economic, social &
environmental issues of the wind and grid planning & development. An examination and
resolution of these issues is a prerequisite to any location, setback, noise and flicker discussion.
The guidelines should be based on an independent, transparent cost benefit analysis for wind
derived electricity for both domestic and export projects. The development of renewable energy
sources, together with measures aimed at a reduction and more efficient use of energy are on a
national & European level, on both environmental and energy policy grounds. The
implementation of renewable energy policies must have a regard for the environment.
Ireland is obliged to take appropriate steps to avoid pollution or deterioration of habitats or and
disturbances affecting communities and wild life.
The Issues
With respect to residential communities, the most critical consideration of on-shore Industrial
Wind Energy development relate to:
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the potential impact to natural heritage, including site drainage and hydrological
consequences to bogs/land being filled with mass concrete. Impacts on groundwater etc.
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
Electromagnetic interference, particularly on medical devices including pacemakers,
cochlear implants, which are impacted/effected by magnetic forces.
the overall impact on the landscape and general amenity of residents.
the fact that no economic analysis in the form of a cost benefit analysis has ever been
carried out in Ireland. The Wind Atlas for Ireland acknowledges that wind speeds are
low for proposed Wind Farm sites in the Midlands.
no overarching strategic assessment of the impact on our environment or landscape
from this enormous plan has ever been performed.
disposal or elimination of waste/decommissioning process. Will all traces of the
Developments, included mass concrete be removed within a respectable time frame?
Firm guidelines need to be in place.
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 our view, thus far, that the balance is firmly in favour of the
developments and significantly removed from community concerns.
The recommendations below, as underlined, must be incorporated in the final draft of the
guidelines.
(A) Noise limits
It is noted that ‘the impact of wind energy development noise is likely to be greater at low wind speeds’ with
areas ‘down wind experiencing the highest predicted noise levels’. It is also acknowledged that ‘emphasis
should be on preventing sleep disturbance’. What protocols are in place to address this issue if local
residents do indeed suffer sleep disturbance following Turbine operations?
The Guidelines are too vague and fail to offer the community adequate protection or security.
The Guidelines should adopt the World Health Organisation’s guidelines on Community Noise.
The noise from Wind turbines is continuous and should come under the same guidelines as all
continuous noises in the community. There is no justification for disregarding public health
priorities by applying different measurements to satisfy purely economic ends. The WHO states
that if negative effects on sleep and adverse after-effects are to be avoided, 30db should be the
maximum level measured in a bedroom with open windows. The WHO also advises that where
the noise is composed of a large portion of low frequency noise (i.e. the noise from wind
turbines), a lower value should be operational. Where background levels are low, a lower
guideline again is strongly recommended. (http://www.who.int/docstore/peh/noise/Comnoise4.pdf).
 Based on the WHO guidelines, the Council should adopt a daytime and night-time
maximum increase of no more than 5db above ambient sound with the windows open.
Raising the permitted sound limits for “national and global benefits” is a short term view.
Doing so ignores the potentially negative health implications and subsequent financial
burden that will be placed on communities and ultimately on local authorities and the
government.
 The noise guidelines (Wind Energy Development Guideline, 2006) apply only to wind
speeds of 6 and 8 metres per second at 10 metres height. Given the typical relationship
between wind speed and noise, a focus on limits at these two wind speeds has been
deemed sufficient. With modern electronically controlled turbines, this relationship can
be modified so that turbines comply with the limits at the two wind speeds, while
emitting more noise than expected at other wind speeds. There should be a requirement
that the electronic control is not only used to keep the noise level low, solely at these two
wind speeds, in accordance with the guidelines, but are also used on a broader spectrum
to ensure adequate noise attenuation at other speeds. For example, regulations should be
introduced to set maximum noise levels applicable irrespective of wind speed.
 It is customary to put up turbines which only comply with the noise requirement if they
run in a power-limited mode. It should be made clear that the turbines are permitted to
run only in the mode for which the noise is approved i.e. they should be disallowed from
running in conditions which breach noise limits.
 For all large wind turbines, the low frequency contribution is significant, and it is
therefore important to be weighted correctly in all calculations. In calculations of the
total A-weighted sound pressure level, the slightly higher figures for the ground
reflection at low frequencies should be included.
 Calculations and granting of tone penalty should be stated.
 While it is appropriate to measure noise close to the turbine and calculate the noise
measurements in neighbouring houses, instead of directly measuring there, it must be an
absolute requirement that the calculation is performed based not merely on the “best
case scenario” but on the best variable knowledge available where the projected tolerance
bands are included.
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There is no provision in the plans regarding the ongoing independent monitoring of the
noise levels to ensure compliance. Similarly it is not known if the there are the
capabilities or the budget to engage the services of suitably qualified contractors. There
needs to be clearly defined procedures, including maximum response times for dealing
with complaints relating to noise from turbines, bearing in mind that such noise is unique
and presents technical challenges compared to conventional sources of noise pollution.
There are no values for the noise generated during the erecting and testing stage. The
noise experienced at the testing stage can be 50% above acceptable levels. Where there is
multiple wind turbines, this increase in noise level most certainly will exceed
recommended levels.
The present limits were made for smaller one-off turbines, typically up to 50m. There is
no provision in the county development plans for large scale farms, how they are going
to measure the accumulative sound and the related health implications.
There is no provision in the Guidelines demonstrating how they are going to determine
the measurement criteria and technique to accurately assess the cumulative effect of two
or more turbine blades in synchronisation with each other (which can in some cases
double the sound).
The measuring technique needs to be defined in accordance with international best
practice to ensure that knowledge of how limits are devised can be considered credible,
particularly in light of public health concerns. If the A-Weighted measurement is used it
needs to state that the low frequency measurements will be included in the final values.
At control measurements, the measurement uncertainty must be added to the measured
value before it is compared to the limit. Only then can the turbine operator show that the
limit is not exceeded.
A survey by Davis & Steigler (2010) of over 17,000 children who have Autistic Spectrum
Disorders (ASD), indicted that over 40% were ‘hypersenstive to sounds’ and that ‘noise
sensitivity is a particular problem’ for children with ASD.
An article in The BMJ by Niehaus & Tebbenjohanns, (2001) acknowledges that ‘Electromagnetic
radiation may interact adversely with implanted pacing systems and implantable cardioverter-defibrillators
(ICDs)’.
We would consider that the government make it a requirement in the issuance of guidelines to
planning authorities that a thorough impact on autistic children, and effects on medical devices
as previously mentioned, be assessed.
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. Disregards the noisiest 90% 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.
(1) 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:
Page 90 of this 10.9 MB report from Scotland recommends a 10,000 m exclusion zone. The
University of Paris recommends 3.1 miles or 5,000 m. Some of the following distances use an
assumed rotor diameter of 100 m & a total height of 150 m, based on a 2.5 MW turbine. Note
that 1 mile = 1609.344 m and that 1 foot = 0.3048 m.
Given that these are recommended by experts we should not be so hasty by allowing inefficient
setback zones, purely to hasten these Wind Farm developments and end up ‘paying the price’
later.
A default set back of 10 x base to tip height is required is recommendation is based on
conclusions by many experts, such as Dr Chris Hanning, 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 Yano 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 set-point, 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. Are the government convince that Shadow Flickers does not in any way harm or invoke
negative effects on individuals, motorists, people with medical conditions (including
autism, epilepsy etc), animals? Are they prepared to accept the full responsibility if future
research demonstrates such effects given the indications that are currently proposed?
2. 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.
3. The Guideline revision does not prescribe mandatory conditions for eliminating Shadow
Flicker incidence on dwellings. Mandatory elimination is a must.
4. 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.
Conclusion
There is not only a legal but also a moral obligation on The Government to ensure the
welfare, health and prosperity of all of its citizens (rural and urban-dwelling) in the
adoption and implementation of any and all renewable energy developments in the
future. This obligation is significant and compelling in relation to wind farms given the
overwhelming evidence concerning their adverse effects on the health and wellbeing of
the population as pointed out in preceding paragraphs, inefficiency at reducing CO2,
expense to the consumer and negative impact on property values.
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. As the human ear does not disregard 90% of noise experienced, then
this measurement indicator is considered inappropriate for Wind Turbine noise measurement.
LAeq is the energy average of the noise over a given period.
Name:
Address:
Ailish Ridgeway
Date: 19 . February 2014
Garryhinch, Portarlington, Co Offaly.