Submission to Health Canada Wind Turbine Noise and Health Study, 2012
Please acknowldge receipt of this comment.
The wind industry is meeting strong opposition from communities.
Earlier this year it was discovered the federal government was about to weigh in on provincial policy by establishing national guidelines on wind turbine setbacks. It was revealed by a government official they were planning to adopt the setback regulations being used in Ontario and set in 2009 in the Green Energy and Economy Act. They also supported noise levels of 45 dBA and cite noise masking as an instance to allow even higher levels.
These setbacks are inadequate and they were imposed without any due diligence or response to the many families who were and are still being harmed by industrial wind turbines and substations being situated too close to their homes, causing them to become ill with some having to abandon where they live. Ultimately the federal working group disbanded.
There has been much independent peer reviewed research of evidence on health impacts by industrial wind turbines and their substations provided to the provincial and federal governments. This includes up to date information and work that has been done on the ground and in the field.
First hand testimonials and correspondence by residents requested and urged intervention by the federal government in a provincial policy.
Thankfully the federal government listened and when the announcement about the study initiative was released most everyone welcomed it and felt relief to have their involvement.
However, a read through the Health Canada website information on this study has raised some concerns that many may not take notice of but have put some living in the middle of the projects and some expecting projects in their area on alert.
The federal government is acknowledging that families are being harmed in industrial wind turbine facilities. They have had first-hand testimonials delivered to them through their MP's and directly to senior officials.
Provincial ministers and ministries have been inundated with complaints; there has been formal testimony before the standing committee on the Ontario Green Energy and Economy Act, to many municipal councils and so on. Government representatives have also been invited to many community based meetings to receive up to date information and hear the resident's concerns and they have met with residents individually. Thousands of complaints have been ignored by the province(s).
"Health Canada is aware of health-related complaints from individuals living in close proximity to wind turbine establishments. The study is being designed with support from external experts, specializing in areas including noise, health assessment, clinical medicine and epidemiology."
"Beyond the auditory threshold, low frequency sound is more annoying than that at higher frequencies. It also travels further than higher frequency sound, and can penetrate structures such as homes without much reduction in energy. Low frequency noise can create indoor noise problems such as perceptible vibration and rattle."
With this acknowledgment of harm it is incumbent on the government to impose an immediate moratorium on any new wind projects and to mitigate the problems in the current ones that are causing harm and distress to Canadian citizens today.
As it sits, this study is proposed to take approximately 2 years leaving those suffering to continue living under very serious adverse conditions and is still allowing more turbines to be built, putting even more Canadian families at risk.
With a moratorium and mitigation measures implemented a study could begin. Without this in place the trust that this is genuine and in the best interest of those suffering is diminished and is no different than the place we are at with the provincial government. Their 5 year research chair initiative hasn't started in over 2 years of development and yet we witness more projects being approved and IWT's being erected.
This study introduction starts with a description of the goals of the wind energy proponents and our government, literally putting their concerns first in line. Wind energy is labelled "viable" and "environmentally friendly". The federal government has a monetary stake in wind development having given millions of dollars in repayable and non-repayable loans to wind energy companies through NRCAN. Of course they are also under pressure by lobbyists to continue the proliferation of turbine developments. I find the tone of this introduction inappropriate with the launch of a study of this nature.
Wind turbines (WTs) are becoming an increasingly common power generation option across North America and in many parts of the world. This source of energy is viewed as a viable and environmentally friendly alternative to fossil fuels. Since the announcement of the Government of Canada's renewable energy initiatives, there has been a steady rise in the number of WT installations across Canada. Wind capacity is currently surpassing 5.4 Gigawatts (GW) - enough to power over 1.2 million homes. By 2015, wind capacity is expected to reach 10 GW, which is a 20-fold increase over 2000 levels. By 2025, it is envisioned that 20% of Canada's electricity will be wind power generated (Canadian Wind Energy Association, 2005).
The comment highlighted below is inappropriate and offensive and it suggests that wind turbine noise may disturb "sensitive individuals". This is an insult to those who are being affected by noise levels that may be in or out of compliance, victims of loud cyclical noise when they are trying to sleep. They also acknowledge exceedances which should be cause for immediate shutdown but doesn't happen for victims. This also doesn't touch on the addition of low frequency noise which may be inaudible but disturbing.
The WHO's Night Noise Guidelines for Europe (2009) cites sleep disturbance as a potential indirect health impact of environmental noise for yearly averaged night time outdoor sound levels at the residence higher than 40 A-weighted decibels (dBA). There are studies which report that this sound level may be exceeded at some residences, suggesting the potential for WTN to disturb sleep among sensitive individuals.
It is noted below a lack of peer reviewed research and self-reported health impacts. In fact there has been much ground work and field study already done by independent health and engineering professionals that has been delivered to our provincial and federal governments and to foreign governments. There are many published, up to date peer reviewed reports and there is overwhelming evidence of adverse health issues resulting from wind turbine and substation start-ups.
This research and the researchers should be included as experienced and knowledgeable partners in the study design.
"Health Canada's ability to provide advice on noise impacts from WTs has been challenged by limited peer-reviewed scientific research related to both the character of WTN, in particular low frequency noise, and a lack of Canadian prevalence data on community complaints and self-reported health impacts from studies with rigorous methodological designs."
The inclusion of the sentence below is inappropriate and unnecessary. Those impacted by noise have not complained about hearing loss. This comment comes from a workplace safety standard and is not pertinent to research on industrial wind turbines. This is confusing for any citizen who does not understand the noise issues related to wind turbine projects.
"Directly, exposure to sound pressure levels in excess of 75 A-weighted decibels (dBA) could result in hearing loss, depending on the duration of exposure and the sensitivity of the individual."
The sentence below is not correct and will mislead the public. WHO's night time guidelines do not reflect the type of noise created by wind turbines. Turbines create a cyclical, whooshing modulated noise which cannot compare with the smooth even linear tone of traffic or passing aircraft. The Ontario government, backed up by their own ministry field officers should be applying a 5 dbA penalty to noise emitted by wind turbines. Ministry field officers, based on their knowledge in the field, went to the extent of formally documenting and advising their superiors to apply the penalty and requested acceptable noise levels should be adjusted to 30 to 32 dbA.
"Although the limits in the WHO's Night Noise Guidelines are based on transportation noise sources, current science shows that the same levels are applicable to noise emitted from WTs."
During international scrutiny these flaws will be very easily noted and will cause significant embarrassment to the minister and staff even on an initial review.
The message below is inferring economics may affect the symptoms and experiences of those suffering in wind projects. This is widely used by wind proponents to downplay and dismiss the citizens who are impacted.
This is incredibly insulting and it is hard to believe that this would be included in a federal health study outline.
This mischaracterization of impacted residents is inappropriate and is misleading to the general public.
"For example, it is not clear if those receiving economic benefit experience lower WTN annoyance because they gain financially, or if they began with a lower annoyance and, therefore, were more likely to become participating receptors in the first place. Similarly, the interaction between visual annoyance and noise annoyance is equally difficult to disentangle. In both cases, it is difficult to make causal statements about the relationship between exposure to WTN and community annoyance and, therefore, to set science-based sound level limits."
The federal government launched the announcement of this study and the 30 day comment period in the heat of summer vacation when many Canadians are away from home for extended periods and affected farm families are into summer harvest. Canadians deserve an extension of the comment period into the fall to adjust for this bad timing.
"The research design for this Health Canada study is being posted for a 30-day comment period to allow public review and input. Feedback obtained through the consultation, as well as the responses provided by Health Canada officials, will be compiled and posted on the Department's website in alignment with transparent business practices."
I do not see any inclusion of dirty electricity issues. These have been measured and are known to be causing some of the adverse health issues in some of the homes. This cannot be left out of any study related to industrial wind turbine projects. With all due respect to the appointed health team I urge the inclusion of other independent researchers who have been involved directly with study, evidence and years of valuable interaction with impacted residents. Their wealth of knowledge and expertise in this area is invaluable and they have earned a high degree of public respect for their ethics and compassion.
This will go a long way in assuring affected residents that our government is trusting and empathetic to their concerns.
- Implement an immediate moratorium on the erection of any new or pending wind turbine projects and halt all approvals until this proposed 2 year study has been completed. Resolve all of the current problems in existing wind farms so that the Canadian families who have had to leave their homes can return and all affected residents can once again be assured a safe and healthy environment in their own homes.
- Include independent researchers who have been working on this issue. There are peer reviewed and published researchers who have spent years on this subject and who can add knowledge and expertise to assist the committee in the study design.
- Include some of the residents who have been impacted to assist the design panel. Aside from the many unique situations to take under consideration (gag orders, home abandonment etc.) clearly there are issues with the mischaracterisations, stereotyping and inappropriate wording in this announcement that could have been avoided with some input from those directly affected.
- Extend the comment period for at least 90 days to allow us unpressured comment. Some of those affected are in serious situations and may not be able to react this fast.
More comments will follow.