Submission on the Review of the Wind Energy Development Guidelines.
Dear Sir/Madam,
I believe a “REVIEW” should be a complete review and not on three elements alone. This should only be
carried out after this government have publicly proven a strong case for the requirements of Wind
Developments. I propose that legislation is required to ensure clarity to both residents and developers. It was
with dismay that I read, “Concerns of possible health impacts in respect of wind energy infrastructure are
not matters which fall within the remit of these guidelines as they are more appropriately dealt with by
health professionals”.
Surely health and safety is one of the main reasons there are any Guidelines in the first place?
After having to attempt to read an EIS last month for an SID case in relation to 32 Industrial Turbines, I
cannot stress the importance of ensuring developers identify which turbine they actually intend to apply for
permission for. The developer, in this instance, used various models to base different tests on! ONE turbine
should be named and used to assess the various tests that are required as different models give different
readings.
I will however submit the following and hope that your department will take on board all the information that
is being submitted from the people who will have to live with these developments. I submit that the Wind
Energy Development Guidelines 2006 be revised to require that
Firstly,
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All wind energy developments are first proven to be SUSTAINABLE DEVELOPMENT.
HEALTH must be addressed in this review and, given the reports from around the world and in the
British Medical Journal. The precautionary principle must apply where there is “a social responsibility
to protect the public from exposure to harm”.
SAFETY must be strictly addressed given the numerous accidents that have occurred in Ireland alone.
All EU legislation and directives must be adhered too.
Public Consultation is meaning full and not a tick box exercise.
Wind speeds must be sufficient to ensure sustainable development.
A Property Value Guarantee scheme must be in place
A fund for Community Controlled environmental tests on any house complaining of Noise or Shadow
flicker.
I acknowledge that this is to be a technical review but to me you can’t get a greater understanding of what
residents are concerned about unless you see for yourself and sometimes a picture says a thousand words.
This is the first turbine gone up at Mount Lucas wind farm in Co Offaly. This is 150m high and 800m from
the house in the photo. I do hope you can understand that residents are 100% RIGHT to object to these
industrial machines being located anywhere near their home. The prospect of 32 + 10 within a couple of km
from my home is causing great stress, especially with one 600m away!! And that’s only 2 of the 4 companies
who have plans for the Rhode area.
Now your department is responsible for issuing the GUIDELINES. You tell me how far these industrial
structures should be kept away from your homes? 800m is far too close in relation to the height!
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. 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.
(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.
Set Back Distance:
A default set back of at the very minimum 10 x base to tip height is required. This 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 timesheight 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
vicinityof 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.
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.
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.
Section 34 (2) (a) of the Planning and Development Act 2000 states:
“When making its decision in relation to an application under this section, the planning authority
shall be restricted to considering the proper planning and sustainable development of the area”
In order to consider sustainable development the planning authority will have to assess the economic, social
and environmental issues pertaining to the proposed project when carrying out the Environmental Impact
Assessment in compliance with Article 3 of the EIA Directive.
In addition, the Department of Environment Heritage and Local Government issued the Wind Energy Planning
Guidelines WEPG (DEHLG 2006) which state:
“The development plan must achieve a reasonable balance between responding to overall
Government Policy on renewable energy and enabling the wind energy resources of the planning
authority’s area to be harnessed in a manner that is consistent with proper planning and
sustainable development.”
The revised Guideline state 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
entire Guidelines as they currently stand, promotes irresponsible on-shore wind development. The Guidelines
should be based on an independent transparent cost-benefit analysis (CBA) for wind-derived electricity for
both domestic and export projects.
Yours truly,
Joanne Addie.