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 nonrural activity.
Considering the size and scale of modern day turbines the setback should be at least 2Km.
Under no circumstances should there be any ‘Exception to Setback’ a home owner should not be
allowed to sign a consent form stating that they agree to a turbine been sited less than the minimum
allowed distance from their dwelling. This is wide open to Coercion and corruption.
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 our observations and in particular our opinion
regarding the limited scope of this revision.
Yours Faithfully
Pat Madden