XXXXXXXX
XXXXXXXX
XXXXX, Birr
Co. Offaly
14 February 2014
Wind Submissions,
Planning section,
Department of the Environment, Community and Local Government,
Custom House,
Dublin 1.
To whom it concerns,
I believe that is imperative that any review of the Guidelines also examines all economic,
social and environmental issues of wind and grid planning and development. An examination
and resolution of these issues is a prerequisite to any location, setback, noise, flicker
discussion. In my opinion the government has failed in its reassessment of the guidelines
based on the narrow focus of the review.
It is imperative that any review of the Guidelines also examines all economic, social and
environmental issues of wind and grid planning and development. An examination and
resolution of these issues is a prerequisite to any location, setback, noise, flicker discussion.
Setback
Setback should be determined by factors identified as issues in the sustainability assessment.
For example setback will be influenced by the social costs of a development. These costs
include monetised values such as lowering of property (land and housing) values
(Heintzelman and Tuttle, 2012) as well as ‘non-monetised’ externalities such as noise
(Nissenbaum et al., 2012), shadow flicker (Harding et al., 2008), the loss of amenities and
visual destruction of the landscape (Ladenburg and Lutzeyer, 2012).
Residents of rural housing in the immediate vicinity of the proposed wind farm sites enjoy a
wide range of amenities that contribute to residential property values in this area such as high
natural and scenic value, quiet rural environment, and freedom from significant industrial or
non-rural activity.
Property Values
There is increasing recognition of the negative impacts of wind farms on nearby houses. In
particular,
Linconlshire Valuation Tribunal (2525475645/032C and 2525475651/032C) upheld an
appeal to downgrade a dwelling to a lower council tax band due to the proximity of a wind
farm which was 930m from the house in question. The findings of the appeal explicitly states
“Case law and experience elsewhere had shown that dwellings which were located in close
proximity to wind farms had seen their property prices drop by around 20%.”
The stated key objective 5.6.1 of the Guideline aims, “to seek to achieve a balance between
the protection of residential amenity of neighboring communities in the vicinity of wind
energy developments, and facilitation of the meeting of national renewable energy targets”.
However, we believe that a key objective should be the protection of sleep. Sleep is a human
right, not an amenity as stated and cannot be protected by a 40dB absolute limit.
Noise
I would consider it mandatory that the Government make it a requirement in the issuance of
guidelines to planning authorities that a thorough impact of sound be commissioned on the
wider community.
I believe it would be more appropriate to require the implementation of the Danish statutory
requirement that low frequency noise would not exceed 20dB (A) inside a dwelling any time
of day or night.
The proposed guideline limit of 40dB(A) is also at the top end of the limit recommended in
the Marshall Day report commissioned by SEAI (2013), where a limit of between 35dB(A)
and 40dB(A) is recommended. 40d(B) is also higher than any of the other jurisdictions in the
Marshall Day report, once the limits are adjusted to bring them into line with LA90, as
opposed to LAEQ, which is assumed to be 2dB higher.
If an absolute limit is to be used, it should be at the lower end of the limit, because of the
relentless noise generated by wind turbines. Otherwise, it would be better to use a relative
limit which takes into account the quiet nature of many locations where it is proposed to build
Wind Turbines.
Shadow Flicker
The strategy points out that shadow flicker “occurs inside buildings” it make no provision for the
occurrence of flicker on the open country side. Surely consideration should be given to the potential
distracting and dazzling effect that this will have on drivers and other road users, amenity users and
wildlife as well as livestock and domestic animals. This point is very clearly illustrated in the
following video which was filmed in Wisconsin, USA and it speaks for itself.
http://www.youtube.com/watch?v=MbIe0iUtelQ
Impacts on Autistic Children living in the vicinity of the site.
A survey by Davis and Steigler (2010) of over 17,000 children who have Autistic Spectrum
Disorders (ASD) shows that over 40% were “hypersensitive to sounds” and that “noise
sensitivity is a particular problem” for children with ASD.
I would consider it mandatory that the Government make it a requirement in the issuance of
guidelines to planning authorities that a thorough impact on autistic children be assessed.
I hope that the government will take cognisance of my observations and in particular my
opinion regarding the limited scope of this revision.
Yours faithfully,
Teresa Ryan-Feehan
Mobile: XXXXXXXX
XXXXXXXXXX@gmail.com.