1

To the Secretary of An Bord Pleanla

64 Marlborough Street, Dublin 1
Public Third Party Objection Submission Objection on the Castletownmoor Wind Farm SID Application,
PA0046: Co. Meath.

Castletownmoor Wind Farm consisting of 25 no. turbines, a 110kV electricity substation and associated
works, Co. Meath. Case reference: PL17.PA0046
Case type: Application for permission (S.37 Application)
Applicant: North Meath Wind Farm Limited
Dear Secretary,
We the undersigned wish to make a Submission (Objection) in relation to the above application for the
construction of a 25 Turbine Wind Farm, near Kells in County Meath, as a group, by way of a group
submission to object to this proposal. We nominate the following person as a point of contact for our
group,
Contact details:

Name: John Callaghan

10 The Cloisters, Oldcastle Road Kells, Co. Meath 086 8731707

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Introduction.

The Castletownmoor Windfarm proposal is an application for a constituent part of the previously
refused Emlagh WindfarmProposal.
This 25 turbine proposal was granted Strategic Infrastructure Status in May 2016 despite the fact that
the very same 25 turbines were refused planning permission last February when presented as part of
the 46 Turbine Emlagh Windfarm. There is no substantial difference in the latest proposal for these 25
turbines to justify a planning grant from the reasons that the 25 were refused permission in February
when they formed part of the Emlagh Windfarm Application. As far as residents and users of the
Castletownmoor Footprint area are concerned what is proposed in this area is no different to what was
proposed and rejected previously.
The Bord had discretion to grant the 25 turbines now proposed when they were part of the entirely
rejected 46 Turbine Project. It is submitted that these 25 turbines now proposed are not distinct in any
way from the manner in which they were put before the Bord in the previous application, either by way
of their exact location, height, or diameter of rotor.
The construction and thrust of this Castletownmoor Windfarm Application is to take a portion of the
previously refused Emlagh Windfarm application and to reapply, by way of seeking to take the Bords
Grounds for Refusal of Emlagh, and to ask the Bord to apply different weightings such as to tip the
balance in favour of the applicant this time around.
The applicant is seeking to functionally appeal the Emlagh Decision, in what must constitute an extreme
breach of process, for such a process is not envisaged in the SID Act,
If the applicant contends that the Bord misunderstood policy and reached the wrong or irrational
conclusions then, they should they have proceeded by way of Judicial Review, after the Emlagh Decision
seeking to strike down the irrationality of the Bords Decision. The Emlagh Decision was not challenged
and it stands and that decision to reject all turbines must now be deemed to be persuasive and rational,
and it must be deemed to be a strong Planning Statement based on Rational Grounds and reasoning.
This application makes several references to the Emlagh Application such as to compare the two in so
many ways.
The Emlagh files are no longer available online, and that this must put members of the Public at a severe
disadvantage in commenting on the documents submitted. Given the enormous cost of the Emlagh and
Castletownmoor application documents the non-availability of the Emlagh documents online is a serious
deficiency that should in its own right. Given th e very large volume of material in the application and its
complexity accessing the material in th e Bords Office is not feasible or sufficient.
There have been problems too with the availability of the Castletownmoor Documents online as they
were not always available. The Bord refused additional time to make submissions. This difficulty has
been communicated to the Bord.

The Reasons and Considerations of the six members of Bord Pleanla which previously refused all 46
turbines comprising the Emlagh Application must logically apply to the Castletownmoor Application

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because the 25 turbines which comprise the Castletownmoor proposal are exactly identical to 25 of
the turbines which comprised the Castletownmoor Cluster of the Emlagh Proposal. Referring to pages
1& 2 of the Board Direction in Ref: 17.PA0038 available at
http://www.pleanala.ie/documents/directions/PA0/SPA0038.pdf

REASONS AND CONSIDERATIONS

Having regard to:
the Wind Energy Development Guidelines, Guidelines for Planning Authorities (Department
of the Environment, Heritage and Local Government, June 2006) and, in particular, the
provisions of Chapter 3 Wind Energy and the Development Plan and Chapter 6, Aesthetic
Considerations in Siting and Design;
the policies and objectives of the Meath County Development Plan 2013- 2019 including,
inter alia, in respect of renewable energy, wind energy, tourism, cultural heritage, protected
structures, views and prospects and landscape character assessment (noting the lack of a
Wind Energy Strategy in the Plan);
the need to treat wind farm development in this area with particular sensitivity given the
proximity of the development to a large number of houses located in the open countryside and
within a network of existing villages at Moynalty, Carlanstown, Castletown, Lobinstown and
in the nearby town of Kells;
the location of the proposed development in an area with a history of settlement and an
associated legacy of places and features of cultural importance from many historical periods;
the character of the receiving landscape;
the scale, height and number of the proposed wind turbines;
the submissions and observations received in relation to the proposed development, and
the report and recommendation of the Inspector,
Board Direction
it is considered, that a windfarm of the scale, extent and height proposed would visually
dominate this populated rural area, would seriously injure the amenities of property in the
vicinity, would interfere with the character of the landscape and would not be in accordance
with the overall development objectives of the current County Development Plan.
Furthermore, it is considered that the proposed development would not align with the Wind
Energy Development Guidelines as this guidance document did not envisage the construction
of such extensive large scale turbines in an area primarily characterised as a hilly and flat
farmland landscape and in such proximity to high concentrations of dwellings. The proposed
development would, therefore, be contrary to the proper planning and sustainable
development of the area.
In deciding not to accept the Inspector's recommendation to grant permission, the Board
considered that, notwithstanding the provisions of the National Renewable Energy Action
Plan, and other national and European Union policies in support of renewable energy
development (including wind), the impacts of this very large development on the substantial
local residential population, and the impacts of the proposed development on landscape and
cultural heritage, would not be acceptable in this location. The Board further considered that

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the number and height of the proposed turbines would significantly exceed the landscapes
medium potential capacity to accommodate windfarm development as set out in the
Landscape Character Assessment of the County Development Plan.

The Need for the Project (Non-Technical Summary 1.2)

The applicant has set out the following reasons as supporting the need for the project:
The need for the proposed development has been cited by the applicant as driven by the following
factors:
1. A legal commitment from Ireland to limit greenhouse gas emissions under the Kyoto protocol to reduce global
warming Comment
COMMENT: The most effective ways of reducing Co2 emissions and GHGs

is to stop using fossil fuels coal and peat in Ireland for electricity generation and industrial.
processes by switching to natural gas and higher efficiency generation with use of waste heat such as
CHP.

run more trucks and tractors on natural gas rather than diesel with lower emissions.

limit methane, nitrous oxide emissions from agriculture and waste streams.

use solar thermal heat for water and space heating with inter-seasonal storage.

make more use of heat pumps and better insulation for the heating sector.

t CO2/SEAI Pu
SEAI

SEAI publish the following Emission Factors for CO2 intensity of Fuels

Page 29
http://www.seai.ie/Publications/Statistics_Publications/Energy_in_Ireland/Energy_in_Ireland_Key_Statist
ics/Energy-in-Ireland-Key-Statistics-2015.pdf

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Milled peat used for power generation at 33% efficiency would indicate a CO2 intensity of 420/.33 =1272
grams of CO2/kWh of electricity
Coal used for power generation at 40% efficiency would indicate a CO2 intensity of 340.6/ 0.4=
851.5grams of CO2 per kWh of electricity
Gas used for power generation @ 60% efficiency (CCGT Turbine) would indicate a CO2 intensity of
204.7/0.6= 341.16 grams of CO2 per kWh of electricity
Gas used for power generation @ 30% efficiency (OCGT Turbine) would indicate a CO2 intensity of
204.7/0.3= 682.33 grams of CO2 per kWh of electricity.
Net CO2 intensity of Irish Electricity is 456.6 grams of CO2/kWh
CO2 of imported electricity is 0 grams of CO2/ kWh because the CO2 output of imported electricity is
returned in the Country of Generation for CO2 accounting purposes.
CO2 Reduction is deemed by the Commission to be the most important of the 2020 Energy & Climate
Targets and it should not be adverse impacted in order to assist renewable targets.
Electricity production form Coal is highly profitable for the ESB contributing several hundreds of millions
in annual profits. Electricity Production from Peat is underpinned by large subsidies and it is neither
economic nor environmentally responsible.
The case for inflicting wind turbines in close proximity to people, on landscapes, inflicting property
devaluation and trespass zoning cannot be justified while such ridiculous energy policy is pursued.

http://www.seai.ie/Publications/Statistics_Publications/Energy_in_Ireland/Energy_in_Ireland_Key_Statist
ics/Energy-in-Ireland-Key-Statistics-2015.pdf
2,686,530 tonnes of CO2 are emitted each year from burning peat to generate electricity. 2/3 of this could
be saved by switching from peat to CCGT based Gas power generation.
The Bord are requested to examine the CO2 saving arising from abandoning coal in favour of CCGT based
Gas power generation such as to demonstrate the irrationality of current generation practice ?

The need to reduce our Green House Gas emissions also arise under our EU obligations under the EU
Energy and Climate Package. Agriculture is the largest emitter in th e non ETS sector.

http://www.epa.ie/pubs/reports/air/airemissions/2020_GHG_Projections_2016_Bulletin.pdf

It is estimated that non-ETS sector emissions are projected to be 9% - 14% below 2005 levels by
2020. This compares to the target of 20% below 2005 levels by 2020. Ireland is obligated to cut
Agricultural Emissions to reduce GHGs but instead is vastly expanding Agricultural production.

http://www.epa.ie/pubs/reports/air/airemissions/2020_GHG_Projections_2016_Bulletin.pdf

http://www.epa.ie/pubs/reports/air/airemissions/2020_GHG_Projections_2016_Bulletin.pdf
The Developer claims the proposed 85MW windfarm will save 115,000 tonnes of CO2 per year, which
assumes a name plate capacity of 3.4MW per turbine.
The Developer relies on a CO2 saving of 460 grams per kWh. This equates to 250,000MWh of electricity
per year and a capacity factor of 33.55%
If the power production is to be at the upper end of the envelope, then Sound Emission Power Levels
will be high too. There is no certainty as to the type and size of turbine to be used here and so there can
be no certainty on CO2 saving or impacts. Because Critical Wind speeds are different for each turbine
and each location it is not possible to determine the impact of the turbines without fixing the turbine
type Refer to Section 4.2Assessing noise from wind farm developments in Ireland: A consideration of
critical wind speeds and turbine choice (E.A. King, F. Pilla, J. Mahon)
http://www.sciencedirect.com/science/article/pii/S0301421511008937
The Site description in the Non-Technical Summary does not refer to the intended land use during the
life of the windfarm over the 702 hectares. Is Beef farming to be the main use of the site along with
wind power production? Beef production has an output of about 1000kgs per hectare which would
allow about 702 tonnes of beef to be produced a year on the wind farm. The GHG emissions would
logically be offset against the carbon saving of the windfarm. If 2.75MW turbines were to be used as
opposed to 3.4MW turbines then the claimed CO2 saving as determined by the Developer would be
87,940 tonnes on the basis of 460 grams per tonne. CCGT Turbine at 60% efficiency without CHP can
produce electricity at a CO2 intensity of 187/0.6=311grams per kWh of electricity. The use of coal and
peat based electricity generation raises Emissions per kWh excessively as does the failure to deploy CHP
generation to make use of the waste heat and displace fossil fuel. Ireland has obligations under the
Waste Framework Directive and the Energy Efficiency Directive to generate electricity more efficiently
and to make use of the energy lost in the thermal conversion process.
The Developers 460 gram per kWh figure assumes no improvement in the carbon intensity of
generation during the life of the project and that Ireland will avoid its legal obligations in this regard.
Wheatley J. Quantifying CO2 savings from wind power found that Wind Power was only 53% effective
at reducing CO2 when wind penetration on the Grid was much lower than now. Available at
http://www.sciencedirect.com/science/article/pii/S0301421513007829 Wheatley found the CO2 saving
when much less wind was on the grid was 280grams per kWh of wind power generated.

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So for 25 2.75MW Turbines the top line CO2 saving allowing for efficiency impacts on providing back up
generation for wind power the numbers are 250,000MW x 65/85 x 10 x 0.280 tonnes / MWh = 53,529
CO2 saving tonnes.
The Food and Agriculture Organization of the United Nations tell us that the CO2 equivalent in GHGs
of raising beef in Ireland is 19 tonnes of CO2 per tonne of Beef.

See Page 19 http://www.fao.org/3/i3437e.pdf

Gerber, P.J., Steinfeld, H., Henderson, B., Mottet, A., Opio, C., Dijkman, J., Falcucci, A. & Tempio, G. 2013. Tackling
climate change through livestock A global assessment of emissions and mitigation opportunities. Food and
Agriculture Organization of the United Nations (FAO), Rome.
702 hectares of wind turbine site outlined in red on the Application sitemap would have a GHG CO2 equivalent of
19x 702=13,333 tonne of CO2 per year. This deducted from the 53,529 tonnes looks more like 40,000 tonnes of
CO2 saving.
The cost of avoiding 40,000 tonnes of CO2 per year under the ETS regime @ 7.50 / tonne of CO2 is 300, 000 per
year.
The cost of Direct Wind Power Subsidies (ignoring indirect subsidies) above the whole sale price of power
generation is 45/MWh + for each of 250,000 MWh per year would be 11.25 million.

The ETS Carbon Price has been under 10/ tonne since 2011 See figure 5 page 9 of
https://ec.europa.eu/energy/sites/ener/files/documents/quarterly_report_on_european_electricity_markets_q4_
2015-q1_2016.pdf

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However there would be production and other losses attended by consequent loss of CO2 saving from the wind
farm arising from:
a.
b.

c.

d.

e.

f.
g.

running turbines in reduced noise mode to mitigate noise impact (not quantified in th e EIS)
Dispatch down requirements average circa 5% last year say 2500 tonnes of CO2
http://www.eirgridgroup.com/site-files/library/EirGrid/Annual-Renewable-Constraint-and-CurtailmentReport-2015-v1.0.pdf
Very substantial future increases in Curtailment must occur unless there will be extensive exports
through interconnectors. The Winter load profile is described by this graph.

All-Island Generation Capacity Statement 2016-2025: page 26 available at

http://www.eirgridgroup.com/sitefiles/library/EirGrid/Generation_Capacity_Statement_20162025_FINAL.pdf The maximum penetration of
wind power and 950MW of Interconnectors on the All Ireland Grid is 55% of power demand. Already
3021MW of Wind power are connected to the All Ireland Grid and a further 4234MW is contracted for
connection. This would leave up to 7250MW od wind connected to the Grid where the Grid capacity in
winter to absorb power was 1600 to 1900MW capacity requiring massive curtailment or massive
amounts of interconnectors to export power.
The construction of wind farms, transmission and distribution networks, and back up generators incurs a
CO2 foot print. Each MW of wind power has a firm capacity of about 0.1MW requiring 0.9MW of Backup
unless we run wind turbines for the fractions of nameplate capacity they produce at part load. The plan
to use 7250MW of wind to feed winter and summer profile demand involves using 4MW of nameplate
capacity for 1 MW of actual output that can be absorbed by the grid. This means the projected CO2
savings are nonsense, and that the CO2 pay pack period on the resources invested are vastly extended.
It is time that many of our Professionals were made accountable before their Professional Bodies and
that they take a real approach to Sustainability.
It may be well impossible to deliver any CO2 saving from the Castletownmoor windfarm.
Its time too to ask the EU Commission if subsidies can be paid on the same farm to produce CO2 while
subsidies are paid on the same farm to try and avoid CO2.

2. A requirement to increase Irelands national energy security as set out in the Energy White Paper
COMMENT: Wind Power Generation cannot increase energy security as it is not reliable and it cannot be
stored. Thermal storage of solar thermal costs just 1% of the cost of electricity storage. Wind power is
dependent on thermal power plant backup as we have little hydropower and wind power has virtually no
Firm Capacity. The Capacity Factor of Wind Power in Ireland varies substantially by season and in 2010 the
Capacity factor fell to just 24% because of a prolonged spell of very cold weather when output was
negligible at a time which saw maximum electricity demand.

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The State cannot exclude energy imports from other EU Nations or the EU Free Trade area on the basis of
Energy Security, nor can anti-competitive schemes be devised to render any form of State Aid to Irish
Production without specific State Aid clearance.
Justice Donald Binchy has determined in the recent JR Case Callaghan V An Bord Pleanla that
Castletownmoor Windfarm cannot benefit from REFIT and State Aid Clearance has not yet been granted
under the 2014 State Aid for Energy Guidelines for any scheme beyond REFIT. It is submitted that it is not
possible to have any Strategic Infrastructure Objective that is contrary to EU Free Trade and Competition
Principles set out in the EU Treaties. The Energy Self Sufficiency Objectives in the White Paper are no
more than aspirations, pending State Aid Clearance in relation to projects that DO NOT Qualify for REFIT.
It must be remembered that there are several thousand Megawatts of Wind Power capacity that have
Contracted Status with the DSO and TSO. This arises because the Castletownmoor Windfarm Application
st
was not lodged before December 31 2015. Any new Renewable Energy Support Scheme will need to be
approved under the SEA Directive.

3. A requirement to diversify Irelands energy sources, with a view to achievement of national renewable energy
targets and an avoidance of significant fines from the EU (the EU Renewables Directive)
COMMENT: The Worlds Energy Supply has become much more diverse with the advent of
Hydraulic Fracking and with Russian exploitation of Abiotic Reserves. Cheap abundant oil and gas
has driven down coal prices. Ireland now has developed the Corrib Field and most imports are
sourced from Norway, Belgium, Netherlands through the UK, with LNG adding to security of
supply. See the Dukes Report Pages 65 (oil), 99,100(Gas)
https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/552060/DUKE
S_2016_FINAL.pdf
Energy Security can be improved by increasing storage of oil and gas. It must be appreciated that
building more unreliable wind turbines does nothing to secure supply of oil and gas for transport
and heating. OPEC is not a significant supplied of energy to Ireland. The Applicant has
substantially underestimated the amount of wind power connected in Ireland. Current Installed
wind power capacity is 2527.4 MW
http://www.eirgridgroup.com/site-files/library/EirGrid/Connected-TSO-Wind-Farms-01-Sep2016.pdf
https://www.esbnetworks.ie/docs/default-source/publications/dso-connected-energised-windgenerators-Aug-2016 The Applicant cites total installed wind capacity at just 2100MW at page
14 non-technical summary.
Some 1641MW of Wind Power Capacity are Contracted for connection to the Distribution
System with much due to be connected in 2016 & 2017
https://www.esbnetworks.ie/docs/default-source/publications/dso-contracted-wind-generatorsAug-2016
Some 1581MW of Wind Power Capacity are Contracted for connection to the High Voltage
System excepting the P230 120MW Grid Connection of the Applicant of which the applicant
proposes to use somewhere in the range of 62.5 to 85MW of, which now cannot qualify for
REFIT. Many competing windfarms have been granted permission and meet the qualifying
criteria for REFIT and many of these are STATE Owned such as would avoid revenues flowing
overseas to American Investors. Renewable electricity production has surged and it is important
to refer to CURRENY production figures rather than using figures a few years old.
Total Wind Generation for 2015 is cited as 6,536,210 MW which is 562ktoe up 120ktoe on 2014
which had a total of 655ktoe of renewable electricity on a final consumption of 2076ktoe

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The likelihood is that renewable electricity in 2015 was of the order of 655+120 = 775ktoe. This
indicates that excellent progress is being made on renewable electricity towards the 2020 40%
target.

See page 19 http://www.eirgridgroup.com/site-files/library/EirGrid/Annual-RenewableConstraint-and-Curtailment-Report-2015-v1.0.pdf

The Renewable Energy Directive 2009/28/EC has been amended by Directive (EU) 2015/1513.
Under Article 2 any electricity used for renewable transport will be credited at a 2.5 times
multiple. The State Aid and Proportionality Principles of the EU require that the cheapest cost
effective methods are used and the ETS carbon price of circa 7.5 per tonne is vastly cheaper
than the cost of avoiding CO2 using wind power at 200 per tonne of CO21 upwards. The talk of
fines from the EU is nonsense.

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4. Provision of cost effective power production for Ireland which would deliver local benefits.

COMMENT: Wind Power in Ireland is not cost effective power production. Wind power
continues to be supported by State Aid, or subsidies which take the form of
establishment type aid (tax reliefs) and operating aid (production subsidies, preferential
market access, market distortion, negative externalities etc.) The PSO levy was
increased this year simply because gas prices fell to 1.25 cent per kWh and wind power
prices did not. Wind power minimum prices average 70 per MWh plus 10/MWh by
way of balancing payments in direct costs with additional cost inflicted by way of
curtailment and capacity market costs a great deal of which is necessitated by
intermittent wind power requiring back up generation since wind has virtually no
capacity credit.

SEMO Data 16/09/2016 6.05pm

The Irish Wind Industry has so far failed to compete on price and operates as a price
fixing cartel.
The European Commissions Quarterly Report on Electricity Markets (Volume 9issue 1;
fourth quarter of 2015 and first quarter of 2016) indicates the average baseload
electricity price at 33.20/ MWh and that electricity prices track the gas price.

See page 25
https://ec.europa.eu/energy/sites/ener/files/documents/quarterly_report_on_european_electri
city_markets_q4_2015-q1_2016.pdf

This is a development by substantially foreign owned companies which will repatriate

almost the entirety of the subsidies and tax reliefs drained form the Irish Economy to
the Owners of Hudson Clean Energy Partners and General Electric. The tiniest crumbs

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will be distributed to local landowners many of whom live at some remove from the
proposed windfarm. While some rates would be payable to the local authority this is
really money that comes from consumers pockets. GE Turbines can be run from
remote operations centres in Schenectady, New York and Salzbergen, Germany providing
continuous monitoring and diagnostics services 24-hours a day, 365 days a year. See
page 6 https://www.gerenewableenergy.com/content/dam/gepowerrenewables/global/en_US/documents/wind-services/_WindServices_Brochure.pdf

There has been a failure to structure electricity price supports such as to encourage
competition, and to structure supports such that prices are reduced as the capital costs
of near zero marginal cost generators are paid down. Suggestions of beneficially
displacing imports by incurring huge expense through massive subsidies which will be
repatriated to foreign investors lumbering us with dear electricity, trashed landscapes,
devalued property, and a degraded living environment, are beyond silly.

5. Increasing energy price stability in Ireland through reducing an over reliance on imported gas.

COMMENT: Gas powered electricity is much cheaper than wind powered electricity. Gas
demand arises on a variable basis varying with the season and according as wind power
availability drops. Even when wind power output is very low gas is still cheaper than wind by
several times the price of gas generated electricity.
The Eirgrid Dashboard Data for June 10th 16.53 2016 indicates that when 2400MW of wind
power capacity was producing just 50MW of wind power Gas was fuelling generation of 64% of
electricity and the market price was just 33.22 per MWh. The comparable price for wind power
at the time was 80 per MWh plus indirect costs. The Development of Shale Gas in the UK and
the supply form the Corrib Field will influence prices downwards. There is simply no evidence
that wind power keeps gas prices low.
Wind Power requires hybridisation of generation infrastructure since each MW of wind power
must have a MW of back up thermal generation capacity. In addition, duplication and
triplication of distribution and transmission infrastructure must be incurred to facilitate wind
power generation since wind power generators are so dispersed across the Country. Capital
costs carry financing and depreciation costs which must be taken into account and which are
priced into retail electricity prices.
The strategy of increasing wind power production and using interconnectors to offload
intermittently available surplus power while using additional capacity to increase renewable
electricity use during times of low winds is fraught with price risks for Irish Consumers.
The reality is that Irish Wind Power exports are already subject to negative electricity prices
such that revenues and transmission costs are below the cost of subsidies and supports paid to
wind power producers. The most likely outcome is that Irish Consumers will end up subsidising
UK consumers of intermittently available surplus wind power. This has been the Danish
experience. In the long run, creating additional employment in one sector through subsidies will
detract labour from other sectors, resulting in no increase in net employment but only in a shift
from the non-subsidized sectors to the subsidized sector. Energy Security is a concept that is
repeatedly abused as a justification for uneconomic policies and projects such as mass wind
power development.

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Gas Prices are determined substantially by three factors:
(i)
natural gas is an extremely abundant resource in the World;
(ii)
in the long run gas prices are determined by the cost of investing in production and
infrastructure;
(iii) large investments in LNG capacity mean that previously separate markets are more
integrated today and will be even more so in future.

th

Eirgrid Dashboard June 10 16.53 2016

Having regard to the foregoing sections of this document the Bords decision to
grant the Castletownmoor Windfarm SID Status must be deemed to be
irrational and the Bord are requested to de-designate the project as SID Status
as Justice Costello found in Callaghan V An Bord Pleanla ruled a decision to
grant SID Status could be overturned when the Planning Application was made.
The Development should then go through the normal planning process subject

16

to the Planning & Development Regulations should the Developer wish to

proceed further.

The Permission Period (Non-Technical Summary 1.5 Permission Period)

The Applicant seeks a permission period of 10 years:
1. This is far in excess of any period needed to meet the 2020 targets for which there is
sufficient alternative capacity in any event.
2. There has been substantial uncertainty by way of impact of proposed wind power
development in the Kells area since 2012 which has adversely impacted investment
decisions and to inflict 10 more years of uncertainty would be excessive.
3. The EIS study would not remain current or relevant for a ten-year grant, and it would
tend to cause hoarding of grid connection capacity if a 10-year planning commitment
was made.

Site Selection and Alternative Layouts for the Proposed Development (2.4 NonTechnical Summary)
The Applicant has advanced the following reasons for choosing the application Site

1.
2.
3.
4.
5.
6.
7.
8.

an avoidance of environmentally designated areas.

an avoidance of excessive cumulative impacts
siting within suitable areas in County Development Plans
an avoidance of direct impact on Cultural Heritage
suitable wind speeds
proximity to available grid capacity on the Irish electricity network
avoidance of areas with large settlements
adequate access to site and constructability

1. an avoidance of environmentally designated areas.

Windfarms are not prohibited on a Natura Site and there is no legal requirement to discount
using such sites for wind development: Wind farms likely to have an adverse effect on a Natura
2000 site must be subject to an Appropriate Assessment in light of the sites conservation
objectives. Such developments may proceed under certain conditions where the procedural
safeguards foreseen by the two nature Directives are respected. New wind farm plans and
projects may also be subject to the provisions of the SEA and the EIA Directives but these are
distinct and different from the Appropriate Assessment undertaken under the Habitats
Directive. The EU nature Directives and wind farm development anywhere within the EU: the
two Directives also require that Member States protect species of Community interest
throughout their natural range within the EU (cf. Article 5 of Birds Directive and Article 12 of
Habitats Directive see above). Thus any wind farm development must also take account of its
potential impacts on species of Community interest (covered by the two Directives) outside
Natura 2000 sites as well. The applicant has inappropriately discounted considering Natural
2000 and NHA designated sites as alternative sites to accommodate this windfarm. See Wind

17

Energy Developments and Natura 2000 available at

http://ec.europa.eu/environment/nature/natura2000/management/docs/Wind_farms.pdf

2.an avoidance of excessive cumulative impacts. This project was proposed at 46 Turbines in
the range of 120- 160MW initially and even at 85MW will exceed the cumulative size of several
existing windfarms.

The Cumulative impact of this proposed wind farm along with the 70,000 off turbines
built in Europe must be considered particularly on migratory species.
The absence of use of a strategic planning approach will increase the risk of cumulative
impact on bird populations by virtue of the non-use of Bird Sensitivity Mapping to Wind
Energy Development tools.
There Sensitivity mapping does not have data on the proposed site and low risk areas
identified in the Sensitivity mapping project have been discounted as a site for this
project.

See page 21 Bird Sensitivity Mapping for Wind Energy Developments and Associated Infrastructure in
the Republic of Ireland Guidance Document February 2015 available at
http://www.birdwatchireland.ie/portals/0/POLICY/Guidance_document.pdf

There has been a failure to identify windfarms granted permission in Europe that are not yet
constructed in terms of identifying cumulative impact risks.

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The strategy of avoiding areas that already have windfarms by developing in unspoilt areas has
no merit as the cumulative impacts are avoided by thrashing an unspoilt area.

3.
siting within suitable areas in County Development Plans. There are no suitable areas within
Meath for this scale of development identified in the County Development Plan nor indeed in the
Regional Planning Guidelines. The size of the turbines and scale of the proposed wind farm are at the
very upper end of size in terms of wind power development in Ireland. The County Development Plan
referred to medium capacity for development across an area of almost 75% of Meath.

While very extensive areas of the County were deemed in to have a medium capacity for wind
power, given the low wind speeds in Meath, the absence of screening hills, and the Heritage
assets in Meath all these factors would indicated the policy referred to auto generation type
development rather than developments at the edge of scale in terms of turbine and windfarm
size. The proximity of such Medium capacity zoning to Tara and Newgrange indicates that
turbines of a very small size and developments of small scale only were considered. The
capacity designation in the Development Plan and that of the areas near Tara and Newgrange
suggest very moderate development was envisaged by the Medium Capacity Designation in th
e County Development Plan.

19

4.
an avoidance of direct impact on Cultural Heritage. There is no avoidance of impact on
Cultural Heritage in this proposal. There will be a dominating impact on

Headfort House and Demesne

Mountainstown House and Demesne
Bloomsbury House.
Williamstown House Remains
Kells Town
Lloyd Lands Complex
Tara Complex
Newgrange Complex
Loughcrew Complex
Teltown
Rosmeen House
Drakerath house
Dowdstown House

Because of the sheer size and quantity of the proposed turbines. The photomontages have
been limited and those that are provided use low resolution photos and hazed images to
camouflage the project impact. Many alternative sites in Ireland have been dismissed without
rational justification.
5.
suitable wind speeds. The applicant claims that the wind speeds are suitable by
reference to international comparisons, rather than by comparison by other regimes available
at alternative sites in Ireland. Wind power remains heavily subsidised in Ireland with subsidy
costs having recently increased. It is counter intuitive to suggest that a site with the lowest
wind speeds yet developed in Ireland for Wind Power could be a basis for cheaper renewable
electricity. Alternative Sites with higher wind seeds provide the best prospect for the
development of wind power without subsidies, which is a priority objective of the EU
Commission. Eliminating Electricity Subsidies is a key Policy objective for the EU see
COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL,
THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS
Energy 2020 A strategy for competitive, sustainable and secure energy available at
http://eur-lex.europa.eu/legalcontent/EN/TXT/?qid=1409650806265&uri=CELEX:52010DC0639
In order to exploit low level Class 3 wind speeds very tall turbines with very large swept areas
are required that are dominant in the Landscape for much greater distances. Areas with low
wind speeds have wind speeds that are less than 8 metres per second at ground level for about
90% of the year. This has huge consequences for noise impacts on people.

20

6. proximity to available grid capacity on the Irish electricity network. The scale of the
Development tends to exclude use of the Distribution System using medium voltage to connect
to the Grid. Had a number of smaller developments been considered as an alternative this
would have been possible. The decision to concentrate so many turbines in a single
development in one swoop dismissed so many alternatives that would possible have had less
impact on Landscape, Heritage, Wildlife, and with potentially lesser impacts Human Amenity,
Human Health and on Economic Impacts. The utility and capacity of the Distribution System is
substantial for the connection of Windfarms. Article 16. 3 of the Renewable Energy Directive
enjoins the construction and operation of Grid Infrastructure such as Developers of
Renewable Energy are not disadvantaged by using remote sites, in low population areas, for
renewable electricity Development, by way of incurring higher connection and transmission
costs.
3. Member States shall require transmission system operators and distribution system
operators to set up and make public their standard rules relating to the bearing and sharing of
costs of technical adaptations, such as grid connections and grid reinforcements, improved
operation of the grid and rules on the non-discriminatory implementation of the grid codes,
which are necessary in order to integrate new producers feeding electricity produced from
renewable energy sources into the interconnected grid. Those rules shall be based on objective,
transparent and non-discriminatory criteria taking particular account of all the costs and
benefits associated with the connection of those producers to the grid and of the particular
circumstances of producers located in peripheral regions and in regions of low population
density. Those rules may provide for different types of connection.
http://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:32009L0028

It is obvious that if wind power development were to be concentrated in areas that were grid rich it
would tend to concentrate wind power development in areas that had higher population levels. Article
16.3 clearly seeks to avoid the intensification that might concentrate wind power in Grid Rich areas.
Areas with higher wind speeds that could provide wind energy more efficiently and at lower cost in the
longer term might not be developed if policy did not level the playing field by way of extending
infrastructure to high potential areas.
If any weighting is to be given to existing Grid Availability it would tend to making a decision
prejudged or preordained by the very act of creating that grid capacity.

The applicant has been far too conservative in considering alternative sites and the nearest part of the
Windfarm is only 8 km form the potential grid connection point at Gorman. A distance of up to 40km
would have been viable for connection using voltages of the order of 100kv. Such distances are common place
in Europe using XPLE cables and AC Systems.

21

The applicant has a 40 windfarm planning consultation application before the Bord and these sites must
be potential alternatives for this windfarm. Issues of project splitting and cumulative impact also arise.
The Applicant Group also has an Interconnector application before the Bord. The applicant has not
disclosed these issues nor explained how they potentially involve this Castletownmoor project.

When the GATE Capacity and Grid connection was previously allocated to the Oriel Offshore
Windfarm in Dundalk Bay it was envisaged that other potential connection points were viable along
any part of a 30km route north of Gorman. The applicant has not considered other potential sites that
could have been connected to this 120MW of Grid Capacity.
The capacity of the network in the North East Region to connect the output of 25 to 50 wind turbines is
not as limited to a particular location such as Gorman Slane as the applicant maintains.
The alternative sites that can be connected to th eGrid in the North East Region have not been
considered, in accordance with Article 5.3 (d) of Directive 2011/92/EU an outline of the main
alternatives studied by the developer and an indication of the main reasons for his choice, taking into
account the environmental effects;

22

http://www.orielwind.com/uploads/docs/Oriel%20Project%20Presentation.pdf

23

http://www.orielwind.com/uploads/docs/Oriel%20Project%20Presentation.pdf

24

7.
avoidance of areas with large settlements. The applicant purports to be avoiding areas
with large settlements. There is very little consideration of people in the construction of this
proposal. The windfarm is designed and laid out that people will live within the wind farm
rather than around the outside of it, because it is comprised of 6 different clusters sprawled
over a large area. Large numbers of people will live inside or within 1,2,3, kilometres of the
windfarm.

http://airo.maynoothuniversity.ie/external-content/eastern-and-midlands-planning-region

The Area west of Kells and into Westmeath has a much lower population density than the site
chosen by the applicant for the Casltetownmoor Windfarm. The application documentation
under states substantially the size and proximity of the population living within a few
kilometres of this proposed wind farm.

Why is the size and proximity the population in the area being underestimated?
It is obvious that the scale of human impacts must be related to with the size and proximity of
the local population. Section 10.2.1 seriously under states the population size.
Kells is the nearest large town to the proposed development, at approximately 2.9km from the
site. The 2011 population in Kells was 2,208, which is a decrease of 2.2% since 2006ii. The 2011
population of Carlanstown and Nobber were 631 and 357 respectively. These villages are located
approximately 1.5km and 4.4km from the proposed development respectively. Population data
for Moynalty village, located 5.3km northeast of the nearest turbine and 1km southeast from the
nearest turbine, has a population of 116 in 2011.

25

http://airo.maynoothuniversity.ie/external-content/eastern-and-midlands-planning-region

Population figures by area around the proposed Castletownmoor windfarm

1 Kells Urban 2,115
2 Kells Rural 4,654
3 Maperath 463
4 Newtown 906
5 Tailtin 911
6 Donhnach Phdraig 1804
7 Castletown 1,002
8 Staholmog 407
9 Cruicetown 407
10 Moynalty 637

8.
adequate access to site and constructability. There are few areas of the Country that are not
accessible for the construction of wind turbines. The suggestion is that the current site was chosen
because of the difficulty of accessing other alternative sites. While the turbines and blades are of an
exceptional size there are alternatives for shipping these size of turbine blades to other sites. Enercon

26
manufacture segmented rotors of similar length that come in modular pieces such that a rotor for a
126m diameter machine is composed of two parts of approximately 30 metres in length.

The Wind Energy Guidelines of 2006

The proposed development does not accord with the Wind Energy Development Guidelines of 2006
section 6.5 Cumulative Effect
The Castletownmoor Windfarm Site is characterised as Intensively managed farmland, (whether flat,
undulating or hilly) There is little change in elevation across the site and the adjacent lands.
It is preferable to avoid locating turbines where they can be seen one behind another, when
viewed from highly sensitive key view points (for example, viewing points along walking or
scenic routes, or from designated views or prospects), as this results in visual stacking and,
thus, confusion.
Referring to section 6.6 Spacing
Regular spacing is more appropriate for wind energy developments in landscapes of clear
and orderly land cover pattern or unenclosed flat landscapes.
Irregular spacing is more appropriate in landscapes of varied landcover pattern or hilly
and/or rugged landscapes.
Generally, spacing should be of a uniform type in any given wind energy development, rather
than a mixture.
Referring to 6.7 Layout
Generally, layout should be of a uniform type, whether a single line, staggered line, splayed
line, random or grid, rather than a mixture;
The creation of a visual stacking effect from a sensitive viewpoint should be avoided;
Referring to 6.8 Height

27
Turbine height is critical in landscapes of relatively small scale, or comprising features and
structures such as houses, and must be carefully considered so as to achieve visual balance
and not to visually dominate.
Where possible, the perception from more sensitive viewpoints, of turbine blade sets cutting
the horizon should be avoided. (This effect would occur at views from several Heritage assets)
6.9.2 Hilly and Flat Farmland
Key characteristics of this landscape are:
Intensively managed farmland, whether flat, undulating
or hilly;
Apatchwork of fields delineated by hedgerows varying in
size;
Farmsteads and houses are scattered throughout, as well
as occasional villages and towns;
Roads, and telegraph and power lines and poles are
significant components; and
A working and inhabited landscape type.
The essential key here is one of rational order and simplicity, as
well as respect for scale and human activities. The predominance
of field pattern introduces an organised patchwork landcover
structure that not only prompts a similar response in the siting
and design of wind energy developments, but also provides a
spatial structure and rhythm. Although hilly and flat farmland
type is usually not highly sensitive in terms of scenery, due regard
must be given to houses, farmsteads and centres of population.
Siting and design guidance for hilly and flat farmland
Location
Location on ridges and plateaux is preferred, not only to maximise
exposure, but also to ensure a reasonable distance from dwellings.
Sufficient distance should be maintained from farmsteads, houses
and centres of population in order to ensure that wind energy
developments do not visually dominate them. Elevated locations
are also more likely to achieve optimum aesthetic effect. Turbines
perceived as being in close proximity to, or overlapping other
landscape elements, such as buildings, roads and power or telegraph
poles and lines may result in visual clutter and confusion. While
in practice this can be tolerated, in highly sensitive landscapes
every attempt should be made to avoid it.
Spatial extent
This can be expected to be quite limited in response to the scale of
fields and such topographic features as hills and knolls. Sufficient
distance from buildings, most likely to be critical at lower elevations,
must be established in order to avoid dominance by the wind
energy development.
Spacing

Layout

The optimum spacing pattern is likely to be regular, responding to the underlying pattern field
pattern. The fields comprising the site might provide the structure for spacing of turbines.
However, this may not always be the case and a balance will have to be struck between
adequate spacing to achieve operability and a correspondence to field pattern.
The optimum layout is linear, and staggered linear on ridges (which are elongated) and hilltops
(which are peaked), but a clustered layout would also be appropriate on a hilltop. Where a wind

28

Height

energy development is functionally possible on a flat landscape a grid layout would be

aesthetically
acceptable.
Turbines should relate in terms of scale to landscape elements and will therefore tend not to be
tall. However, an exception to this would be where they are on a high ridge or hilltop of relatively
large scale. The more undulating the topography the greater the acceptability of an uneven
profile, provided it does not result in significant visual confusion and conflict.

The applicant has failed to examine the potential of flat peatland to accommodate such a large
windfarm, which afford opportunities to separate wind farms from people.
With a turbine height of 169 metres and a rotor diameter of 130 metres it requires that the rotor tips
move between 39 metres and 169 metres from ground level. The wind shear profile changes a great
deal between 39 metres height and 169 metres height as does the power density as the height varies
from 39 metres to 169 metres height. Such large Rotors relative to total height mean that the rotor
rotates through 77% of the total height of the turbine.
Because the of the very low wind speeds on the site, the wind speeds will be below 8 metres per second
at all height for substantial numbers of the 8760 hours of the year thus minimising the degree to which
higher wind speeds tend to mask turbine generated noise.

The shaded region indicates the region of the frequency field where wind speeds are under 8 metres per second.
The masking effect of 8 metres per second plus wind speeds is very limited by the low wind speed regime at
Castletownmoor.

29

The power density of the wind stream passing through the rotor of such a turbine size and
height will be subject to large variations because power density is a function of velocity cubed
(V). This large variation in power density in the wind shear profile will cause a lot of turbulence
and vibration. It is most unlikely that the noise output tests were carried out in such adverse
conditions.

The close proximity of several turbines to each other will cause further turbines when one wind
turbines is upwind of another.
The EIS Statement contains no data on Wind Direction or frequency distribution. The applicant
has failed to disclose4 or describe climatic conditions at the site.
The following Recitals from DIRECTIVE 2011/92/EU inform as to the intent of the Directive in
terms of protecting people from potential risks, to quality of life, well-being, residential
amenity, and personal health (as opposed to a typical or idealized individual)
(3) The principles of the assessment of environmental effects should be harmonised, in particular with reference to
the projects which should be subject to assessment, the main obligations of the developers and the content of
the assessment. The Member States may lay down stricter rules to protect the environment.
(4) In addition, it is necessary to achieve one of the objectives of the Union in the sphere of the protection of the
environment and the quality of life.
(5)

The environmental legislation of the Union includes provisions enabling public authorities and other
bodies to take decisions which may have a significant effect on the environment as well as on personal
health and well-being.

(14) The effects of a project on the environment should be assessed in order to take account of concerns to
protect human health, to contribute by means of a better environment to the quality of life, to ensure
maintenance of the diversity of species and to maintain the reproductive capacity of the ecosystem as a
basic resource for life.

The Recitals envisage a minimum harmonised level of protection that would apply across all
EU States allowing individual States to apply more stringent standards.
The Irish Wind Energy Design Guidelines refer to ETSU-R-97 but water down the protection
outlines in ETSU-R-97 (however inadequate they are) in order to maximise the potential for
wind power generation. This is done by disregarding a 5 dBA limit by way of turbine noise over
background noise.
Since 2006 turbines have grown much bigger and with increasing rotor size ad there is a
relationship between rotor diameter and noise output.
With 70,000 wind turbine operating within the EU it is not credible that a harmonised
approach envisaged under the Recitals of the EIA Directive for the assessment of wind power
impacts on people, would be based upon or shaped by Irelands Guidelines with other
Nations Guidelines and Regulatory Regimes taking an approach that has much more regard
to the EU Precautionaly Principle.

30

Forecast noise output and actual output differ. Forecasts are generally based on averages and
planning conditions seek to be based on average sound outputs in a period. Peak sound events
tend to influence noise nuisance as does the level of noise over prevailing background noise.
This proposal to develop 3.4MW turbines on the exact same sites for which 25 number 2.5MW
turbines have been refused is astounding.

With increasing turbine size and power output the scale of variation in wind turbine noise
output also increases, on account of:

I.

II.

Actual Climatic conditions and wind shear variations not following the idealisations of
the Wind Shear Power Law, which anticipates wind shear varying with an idealized
Surface Length factor Z0 of 0.055 (see http://wind-data.ch/tools/profile.php ) Where
the Surface Length factor is underestimated it will involve much higher ranges of wind
speed difference between hub height and ground level.
The relationship between turbine emitted sound power output, and turbine power
output. There is a relationship between turbine emitted sound output and turbine
rotor size.

The Study by Pedersen, C. S., Mller, H., & Pedersen, S. (2012). Low-frequency noise from
large wind turbines additional data and assessment of new Danish regulations. In G.
Leventhall (Ed.), Proceedings of Low Frequency 2012. (pp. 181-200). MultiScience Publishing
Co Ltd. Available @
http://vbn.aau.dk/files/227978180/2012_Pedersen_et_al_LF_Stratford_u_A.pdf

General Points of Objection

1. The leftovers of the failed Emlagh Windfarm project which was refused planning permission in its
entirety in respect of 46 turbines, 25 of which appear to be identical to the proposal being presented in
this Castletownmoor Planning Application by way of being recycled in a new planning application.
2. The development by virtue of the enormous size of the turbines proposed and their height will impact
most severely the amenity of the area where we live. The proposal is simply outrageous. The turbines
proposed at 169 metres high and up to 130 metres diameter, and are completely out of scale with the
landscape and the scale in which people live. This development seeks to impose an alien industrial
landscape into an area where land use is predominately residential and farming use.

3. These proposed industrial, structures, so far removed from the understanding of development
in any normal sense and are wholly unsympathetic to the landscape. They are visually
inappropriate structures in an open landscape devoid of screening hills or mountains where the
Planning Authority are minded to restrict the height of a new house to 7.5 metres.

31

4. While it may be argued by some that this type of development is permitted by policy it cannot
be argued that such development is mandatory at the proposed location. The need for this
development at the site proposed arises from the Developer. There has been no acceptance of
the development by the community and no consultation other than to dictate and enforce this
development where it is not wanted. It appears that the Developer intends to continue to wear
down resistance until opposition resources are exhausted.
5. This development cited as 85MW capacity by the Developer in the Non-Technical Summary would be
the largest Windfarm ever constructed in Ireland in terms of Name Plate Capacity. Because of the low
wind speeds at the site the height and rotor dimensions are scaled up such that nameplate capacity
does not really represent the scale due to the large swept area to power capacity ratio. The power
generated per unit of swept area must be low. This has adverse consequences too for resource
efficiency of materials as mandated by any holistic reading of the Waste Framework Directive.

6.

This failed project is being reheated and rebranded to cause confusion. It is outrageous that the Board
allows a rejected application to be rebranded in this fashion and recycled by way of granting it SID
Status and triggering a second planning application following the Oral Hearing and rejection by the
board of all 46 turbines in the Emlagh Development. This wind farm issue has been dealt with at length
devouring considerable resources by way of time reading mountains of documents and attending the
Oral hearing. It would seem that another Oral hearing is before us to resist this proposal and it now
assumed the Board will not meet expenses incurred in making submissions or engaging experts to
advise on this very complex proposal.

7. Objection on the basis that this 25 turbine proposal was granted Strategic Infrastructure Status in May
2016 despite the fact that the very same 25 turbines were refused planning permission last February
when presented as part of the 46 Turbine Emlagh Windfarm. There is no substantial difference in the
latest proposal for these 25 turbines to justify a planning grant from the reasons that the 25 were
refused permission in February when they formed part of the Emlagh Windfarm Application. An
exercise in superimposing the Emlagh site map over the Castletownmoor site map shows that the
turbines are concurrently located on the same locations as in the Emlagh application. The Site
boundaries around the same 25 turbines however have shrunk somewhat. Has the developer
relinquished land subject to original wind options back to farmers?
8. The Bord had discretion to grant the 25 turbines now proposed when they were part of the entirely
rejected 46 Turbine Project. We submit that these 25 turbines now proposed are not distinct in any
substantial way from the manner in which they were put before the Bord in the previous application,
which was refused just a short time before the General Election and that even a grant of a single turbine
in this new application would amount to a most irrational decision by the Board.
9. This in essence is a proposal for very large numbers of people to live inside and or near to a large wind
farm. The numbers of people living within beside and near to the windfarm are misrepresented in the
Non-Technical Summary. The population of Kells, Carlanstown, and Moynalty are massively under
represented. Soo to is the rate of population growth in the General Kells area. The limited size and
density of population was cited as a key reason for the developer to choose the area for a windfarm
development. The under representation of the actual population must have impacted on the decision to
Grant the Project SID status at the early stage. How could a development that was entirely rejected at
full planning stage manage to qualify as strategic infrastructure just months afterwards? It would
appear that a strategy for the developer to reduce the human impact of this proposal is to vastly
undercount the population of the area.

32
10. There has been an inadequate approach to assessing noise impact in this application. The process
followed has not been scientific or rational. Why is noise important? Noise affects peoples health and
also affects peoples right to have proper enjoyment of their homes or other areas like places of
worship, amenities, areas of entertainment and recreation. To spoil enjoyment of these areas you need
to not have nuisance noise. These and other areas including peoples homes are collectively called Noise
sensitive locations.
How should the Planning Process protect you from Noise from Turbines? For the planning application,
it is necessary for the developer through their EIS to describe and establish a noise baseline to protect
human health risks and impacts from noise to Noise Sensitive locations. The proposed 25 Turbines are
located as close as 500m to peoples homes and other noise sensitive locations. These are huge
structures up to 169m high, will take 12-18 months to build, operate over 10-20years and are each and
every one of them a MAJOR development in themselves. They are proposed to be located in a rural area
and NO or almost no existing noise sources exist, while background noise will vary but in most cases the
baseline noise during quiet daytime hours is very low and the area is a quiet peaceful rural area.
What should have happened? In these circumstances background noise readings, you have reasonably
think should have been taken at the nearest noise sensitive locations to each one of the 25
developments that is to say 25 separate readings at a minimum?
The developer instead has used data from old 2014 readings from only 4 locations. Why would the
developer do this?
It is advantageous for the developer to show that this rural area where the turbines are going into is
naturally noisy. In other words, it becomes a key enabler of the project for the developer to show that
the background noise is elevated because it means that higher noise limits can be set and hence larger
scale turbines can be installed and operated to their highest efficiency. One magic cut-off value when
the 4 locations were averaged that the developer needed to get over was 30dB(A). Having <30dB(A)
imposes much lower limits on the developer.
So what actually happened? The 4 locations were averaged using a carefully selected data scrub taking
advantage of a wording loophole in the Irish 2006 Wind Energy Guidelines where the developer has
knowingly ignored best practice called temporal Filtering by included noisier data collected outside quiet
daytime hours. Had temporal filtering been carried out, as is best practice (ETSU-R-97 and IoA GPG), it is
likely that the background levels would be significantly reduced to <30dB(A) at most of the wind speeds.
This is not appropriate practice to say the very least but particularly unfair on the people whose
properties and rights are affected.
So What does all this mean? This development simply cannot go ahead as the noise data supporting it is
flawed, inaccurate and not representative. The noise data simply cannot be relied upon to predict the
impact on peoples health and their rights to proper enjoyment of their properties, local amenities and
their childrens future health. These are major developments, the background noise data is critical to be
accurate and representative, there should have been up to date individual noise readings taken at each
house/noise sensitive location.
The actual noise generated from the turbines we really dont know and people, their homes and noise
sensitive locations will not be adequately protected as a result of questionable practice on behalf of the
developer should this Planning permission be granted.
11. The Bord will appreciate that there are particular hazards to designing windfarms where people are to
live inside them. Noise levels combine from multiple turbines. Such large turbines have high tip speeds
due to large rotor areas- diameters. The Bord will find that noise levels and rotor diameter are related.
This site has one of the lowest wind speeds in the Country. It is of sorts a wind energy desert, requiring
huge rotor swept areas to derive output that would compensate for the low wind speed. The wind
speed data submitted does not provide details of the wind speed and direction by using a wind rose

33
or frequency curve or by using statistics such as average wind speed and shape of distribution
parameters. Neither does the data submitted provide a profile of the wind shear at different wind
speeds, or indeed any assessment of the variation in climatic conditions that change the wind shear.
The applicant has failed to measure and describe the climate at the site or has failed to disclose that
information. Wind speed and direction distribution has impacts and consequences for noise emissions.
This obviously has implications in relation to the EU EIA Directive and the Directive on Environmental
Information. It also raises issues of Constitutional Justice.
12. One of the consequences of the low average wind speed is that the wind speed at ground level will be
less than 8 metres per second for about 90% of the year. This has consequences for adverse noise
impact causing nuisance. The intrinsic noise levels at night are very low and it is proposed to add 20dB
or more to background noise levels. It is not possible to add so much noise without creating a great risk
of noise nuisance. Certainly this practice cannot provide any Scientific Certainty as such as would justify
setting aside the EU Precautionary Principle. While it is recommended to use a surface length
parameter of .05 for calculating the 10 metre wind speed from data derived form a Met mast, for
calculations the actual prevailing ground level wind speeds will be determined by surface length
parameters of the order of 0.1 and 0.2 producing much lower ground level wind speeds than the
idealized modelling. This is the reality of the actual climatic conditions that will influence actual risk of
noise nuisance. Idealized or modelled wind shear profiles based on mathematical models do not hold in
all climatic conditions. Negative wind shear is a reality for up to 30% of the time particularly at night.
The British Met Office review 2013 of the Wind Atlas confirmed the phenomenon.
13. The setback distances for wind farms have increased substantially in terms of International Practice the
last few years particularly for large turbines and where the occur in large numbers. Some of the setbacks
follow a simple 10 x tip height rule of thumb distances in Bavaria, Poland. Ohers are more complex
which increase setback distance for 11-25 large turbines to 1500 metres such as those in force in
Ontario, Canada. (Ontario Regulation 359/09 and subsequent amendments 521/10 & 97/16) We say
that this proposal is not considered reasonable or rational by any International Standard. We refer the
Board to the Ontario Regulation 359/09 which sets out a setback distance of 1500 metres for a wind
farm of 11-25 large turbines.
14. The Development while previously described as part of the three clusters of the Emlagh Development is
now as the 25 turbine Castletownmoor development of 6 clusters sprawling over a large area.

While some property owners will benefit the spatial layout blights and devalues 100 hectares of land in
each km near the development. The design layout does nothing to mitigate this devaluation and
reduction of amenity to nearby property. The mere threat of this development snice 2012 has
significantly devalued property in our area and that is a benefit that already runs to the developer. This
is the reality of the threat of trespass zoning. When development can be imposed without agreement
of adjoining residents and property owners it allows a developer to acquire property interests at below
market value since bargaining power is removed. Trespass Zoning amounts to a subsidy for wind power
developers.

15.The New Energy White Paper has set out policy which envisages a spatial analysis as a basis for
choosing wind generation locations and how Grid Resources are to be allocated. This development is
premature to such a process being carried out.

34
ensure that grid connection policy will have due regard to current and future renewable energy
policy, including in relation to community renewable energy projects; this policy, will be defined
using criteria such as scheme size and degree of community ownership
publish a Renewable Electricity Policy and Development Framework (with a spatial dimension)
to underpin the proper planning and development of larger scale renewable electricity
generation development on land. This plan will give guidance to those seeking development
consent in relation to larger-scale onshore renewable electricity projects, and to planning
authorities, statutory authorities and citizens

16. The White paper has extensive statements at paragraphs 89, 90 & 99 has extensive regarding
consultation with communities, and satisfactory outcomes for property owners. While the
Constitution deals with rights as individuals as well as the common good it cannot be held reasonable
that large numbers of property owners can have their amenity and property value diminished by having
this development imposed upon them. The policy recognizes the reality of it not being feasible to
impose developments on communities.
Were this a major Natural Gas Development then the imperative to develop at a particular site would be
much greater. The Policy is stating that it is an objective to have a framework with a spatial dimension to
locate Renewable Energy Development. This Project is entirely Developer lead. Such a framework would
all considerations of where to locate such development that were in the National Interest. The White
paper encourages Renewable Development to meet National Targets BUT it imposes conditions on a
process for selection locations and it requires community support. Government Policy must tend to
influence issues that ultimately are settled in our Courts.

17. The impact of large wind turbines on property values in Ontario is cause for extreme alarm as the
Ontario Supreme Court have already accepted that property devaluation of up to 50% plus is a reality
Wiggins v. WPD Canada Corporation, 2013 ONSC 2350 (CanLII) Please refer to appraisals by Lansink
Consulting
http://www.lansinkappraisals.com/downloads/MPAC%20v%20Lansink;%20McCann%20and%20Gulden
%20Reviews,%20June%202014.pdf The threat to Property Values and Economic Interests far beyond
the Sites controlled by the Developers is real.
18. We respectfully remind the Board of the principles laid down in relation to compensation arising
from construction of necessary electricity infrastructure in the Supreme Court case of ESB v. Gormley
[1985] I.R. 129 and in Underwood v Dublin Corporation [1997]1 IR 69. There is a world of difference
between the reliable kind of electricity that is available for each the 31,577,600 seconds in an average
year, that influenced the Court in that Judgement of 1985, and intermittently available, unreliable
electricity that is available occasionally in varying quantities from wind power, that will often be
incapable of being fed into the National Grid as the grid can only absorb a maximum of 55% of its
electricity from a combination of interconnectors and wind power if the stability of the grid is to be
maintained.
19. Other nations are changing their setback distances because they need to. With near a dozen wind
turbine cases gone to the Irish High Court many farmers face massive potential claims arising from
noise nuisance, or injury based actions and or from property devaluation based claims. Wind
Development Guidelines are not protecting residents and they are not protecting farmers from claims
and litigation. Cases such as Supreme Court of Justice of Portugals Decision No.
2209/08.oTBTVD.L1.S1, 30 May 2013 which ordered the removal of a wind farm.

35
20.A grant of permission with a setback of just 2.95 times the turbine height would set an alarming
precedent for other development in the North Meath area and indeed beyond, particularly with the
applicant group seeking to develop a 1000- 1200 wind turbine export project and considering they have
a live 40 windfarm SID Application and a live SID Interconnector Application before the Board. We are
denied knowledge of the proposed sites for the 39 other windfarms which form part of the Greenwire
Project. These 39 other Planed Windfarm sites must amount to alternatives sites that warrant
assessment as alternative locations for the 25 turbine Castletownmoor windfarm.
21.The impact of large wind turbines on property values in Ontario is cause for extreme alarm as the
Ontario Supreme Court have already accepted that property devaluation of up to 50% plus is a reality
Wiggins v. WPD Canada Corporation, 2013 ONSC 2350 (CanLII) Please refer to appraisals by Lansink
Consulting
http://www.lansinkappraisals.com/downloads/MPAC%20v%20Lansink;%20McCann%20and%20Gulden
%20Reviews,%20June%202014.pdf The threat to Property Values and Economic Interests far beyond
the Sites controlled by the Developers is real.
22. We respectfully remind the Board of the principles laid down in relation to compensation arising
from construction of necessary electricity infrastructure in the Supreme Court case of ESB v. Gormley
[1985] I.R. 129 and in Underwood v Dublin Corporation [1997]1 IR 69. There is a world of difference
between the reliable kind of electricity that is available for each the 31,577,600 seconds in an average
year, that influenced the Court in that Judgement of 1985, and intermittently available, unreliable
electricity that is available occasionally in varying quantities from wind power, that will often be
incapable of being fed into the National Grid as the grid can only absorb a maximum of 55% of its
electricity from a combination of interconnectors and wind power if the stability of the grid is to be
maintained.
23.We object on the basis of the negative impact this project will have on property prices both inside
the footprint of the windfarm and within several kilometers of it. A grant of permission would send
shockwaves through the slowly recovering North Meath Economy, as it would signal that other
developments of this nature were considered reasonable by the Board and would create precedent. The
area has been under threat of this development since 2012.
24. The very fact that this application was entertained by the Board at SID stage raises expectations for
Developers and it encourages yet more speculative applications, which will impact property values in
North Meath and Development Prospects. Kells needs new investment in a new Town Center to reduce
retail leakage form the Kells Retail Catchment Area. These now serial wind power applications are
undermining investment in Kells as its fate seems marked out as Dumping Ground for Export
Orientated Wind turbines.

25.We see no compelling need or reason why such a massive size of a project involving such massive
turbines should be located in North Meath near Kells as at mid-2016 very good progress is being made
on the renewable electricity targets of 2020. 2441MW of Windpower are installed in Ireland currently
and Eirgrid believe that the Wind fleet provided 24% of Irelands electricity in 2015. 2441MW of
Windpower operating at the national average capacity factor of 31% would produce 6,633,319MW of
Electrical Power (570.362kToe). Hydropower produced 61kToe of electricity in 2014 and Bioenergy
produced 152kToe. This indicates that the current level of renewable electricity production in Ireland
is circa 783kToe representing 33.5% of total production of 2338kToe (2014 total production figure
SEAI) ESB and Eirgrids latest lists of Contracted Windfarms show several times the amount of capacity in
development awaiting connection to more than meet the 2020 Targets for electricity. There is no
necessity to grant this application to meet the 2020 targets.

36
26.While the Heat and Transport 2020 targets are substantially short at this time increasing electricity
output is not a solution. The 2050 objectives or indeed the intermediary 2020 and 2030 cannot be
achieved without addressing the need for a renewable heat solution. Any renewable heat solution
must be founded on sound sustainable principles that take account of the Waste Framework
Directives heirarchial mandates that place avoidance / prevention as the top priority in relation to
heating.
27.The County Development Plan zones extensive areas of Meath as having a medium capacity for
windpower. This provisional zoning does not envisage the scale of development proposed by the
developer which is up to (25 x 3.5MW) 87.5MW essentially the same capacity as the 88.5MW
Meentycat Windfarm in Donegal, Irelands largest Windfarm, which uses much smaller turbines due to
higher wind speeds. No Wind Energy Strategy has been conducted in Meath such as would rationally
inform the best use or nonuse of lands in Meath for Wind Farming. Any rational analysis of Wind
Resources in Meath would recommend the omission of this proposed site for wind energy generation.
28.Meath has one of the lowest average wind speeds in Ireland with the wind resource in North Meath
falling into IEC Class 3 a wind speeds. The tips of the blades will move between distances of 39 metres
and 169 metres from ground level. The extensive occurrence of hedges and trees provide a high friction
environment with a surface length Z0 of 0.1 & 0.2 leading to a substantially varying wind shear profile,
and associated energy density variation in the profile of the winds entering the turbines. This is likely to
create high levels turbulence, inducing vibration in blades and the tower structure, with additional
dynamic loading. Noise modeling in this type of environment amounts to idealized guesswork.
29.We object on the grounds that we were not consulted and have not consented to the development
or any part of it, nor have we been consulted nor informed about alternatives. There is no level of public
support for this project among those who live in North Meath. The Developer held a Public consultation
at Kells on April 12th 2016 After the SID consultations with the Board had concluded. This is not real
consultation mandated by the Energy White Paper.
30.We object on the grounds that the Regional Planning Guidelines for the Greater Dublin Region are
contravened by the scale of the development and that no assessment has been carried out to determine
the most efficient location within the GDR for Wind Power Development as recommended by the GDR
Planning Guidelines, given that only 4% of National Wind Resources are reckoned to lie with the GDR
area the majority of which were found to be offshore. Development at this site is premature to a
rational analysis of wind resources within the Greater Regional Area.
31.We object on the grounds that renewable energy development should be directed to those sites
within Ireland or the UK that are most remote from housing, and that such more remote sites should be
used first to meet renewable energy targets.
32.The non-technical summary of the application does not explain how much electricity will be
produced, at what times, for what proportions of the year, to what extent the electricity output could
meet the National Demand Profile.
33.This development will result in an adverse and unacceptable impact on bird life, mammals, bats and
the wealth of our local ecology.
34.Meath has strong links to heritage and tourism. This project does not take this into account and will
damage our tourism and heritage industry resulting in unacceptable long term damage to the historic
and protected landscape. The proposed project is entirely incompatible with the development of the
Ancient East Tourism Product. The Ancient East project recognizes the significance of the Heritage of
Meath, and Kells. The impact of this project cannot be hidden if it is constructed. We are not fooled by
photomontages that are very selectively chosen, often based on using hazy low light photos, taking
pictures form behind buildings walls or hedges which is no more than a farce.

37

35. There are close on 300 acres of lands at Lloyd zoned for Tourism and Recreation at Kells. This
Development will jeopardize that development.
36. The Protected views in the Meath Development plan need to be considered and the landscape
photomontages viewpoints are not well located such as would reflect the real impact of this
development.

37. The Windfarm is located beside the Blackwater Corridor which is designated highest sensitivity in the
2013-2019 County Development Plans Landscape Character Assessment Map 03. This is the site of
Irelands largest windfarm at 85MW and with the largest swept area of rotors.

38.The rich Heritage of Kells and its hinterland is a natural foundation for the further development of its
economy. This development would completely eliminate that course as a realistic prospect. The
Headfort, Mountainstown, and Bloomsbury Houses and their Demesnes will be impacted severely by
this development if granted. They form an important part of our National Heritage, which we must
protect for future generations. Kells the real home of the Book of Kells and its Monastic Heritage will be
impacted by this development. Tourism is a key pillar of the development strategy for Kells.
39.The provisions of the Sid Act and the procedures under which developments are processed offend
against the Principles of Fair Procedure and the Constitution.
40. The 1999 Electricity Act sets out an objective of generating electricity efficiently as does the EU
Energy Efficinecy Directive. Wind power imposes efficiency losses on back up and shadow generation
plant. When allowances are made for these losses wind power is not effective at reducing CO2 and wind
power cannot operate independently of Fossil fuel back up. Wheatley J. Quantifying CO2 savings from
wind power found that Wind Power was only 53% effective at reducing CO2 when wind penetration on
the Grid was much lower than now.
Wind Power costs in excess of 200 per tonne to avoid or save CO2 whereas the cost under the ETS
scheme is under 10/ tonne.
The Treaty on European Union requires a market Economy and Article 3. 3. The Union shall establish an
internal market. It shall work for the sustainable development of Europe based on balanced economic
growth and price stability, a highly competitive social market economy, aiming at full employment and
social progress, and a high level of protection and improvement of the quality of the environment. It shall
promote scientific and technological advance.
If CO2 Reduction is to be taken seriously then the most economic methods must be deployed. Irelands
NREAP was not subjected to the SEA Directive and there has been a significant preliminary opinion from
Advocate General Kokott in Case C-290/15 Patrice DOultremont and Others v Rgion Wallonne on 14
July 2016

38
The proposition that wind power reduces electricity prices is simply nonsense as Gas costs are now
down to 12/ MWh. The Data form the EU Commission shows that gas prices drive prices down.
https://ec.europa.eu/energy/sites/ener/files/documents/quarterly_report_on_european_electricity_markets_q4_
2015-q1_2016.pdf
The CER recently approved increasing the PSO levies to cover the increased cost of subsidies, for Wind power
which costs a minimum of 70 per MWh and 10 /MWh balancing payment plus it creates a necessity for most of
the 700 million per year spend on capacity and curtailment payments.

41. Interconnector Technology continues to advance and we now have options of importing
Hydropower from Iceland or Norway or Geothermal Electricity from Iceland. These power
sources are available on capacity factors of 100% at prices at or under 40/MWh fixed for up to
12 years. The Developer has failed to adequately consider alternative technologies, alternative
sites, alternative layouts, alternative heights. One obvious alternative is smaller developments
connected into the Distribution system rather than a large development connected to Gorman.
There are of course many more alternative sites that could have been used to connect at
Gorman, and the Gorman capacity could be used for Solar PV or Concentrated Solar power with
storage. These can compete on a commercial basis. The UK have plans for importing such power
and that indicates commercial viability for Ireland.
http://www.landsvirkjun.com/researchdevelopment/research/submarinecabletoeurope/

42. The developer makes comparison to between Castletownmoor and the other wind farms such
as Little Cheyene Court at Romney Marsh UK to assert findings in relation to no property value
impact over 5km radius. The 60MW Romney windfarm height is 110 metres and is concentrated
on 4km of land. It is compact and not dispersed The nearest settlements appear to be 1700
metres away. There is no proposal by element to reduce height to 110 metres or to use much
smaller rotors. Using property values over a 10 km diameter area dilutes overall impacts and is
effectively a three card trick.
43. The developer has failed to contain the following information required under the EIA Directive
and in particular under paragraph 7 as specified in Annex IV of the EIA Directive 2011/92/EU.
a. A description of the physical characteristics of the whole project;
b. The land-use requirements during the construction and operational phases;
c. A description of the main characteristics of the production processes;
d. The nature and quantity of the materials used;

39
e. An estimate, by type and quantity of expected residues and emissions;
f.

An outline of the main alternatives studied;

g. A description of the aspects of the environment likely to be significantly affected;

h. Climatic factors;
i.

Architectural and archaeological heritage;

j.

The likely significant effects on the environment from the existence of the project;

k. The likely significant effects on environment from the use of natural resources;
l.

The likely significant effects on the environment from the emission of pollution

m. The likely significant effects on the environment from the creation of nuisances
n. The likely significant effects on the environment from the elimination of waste
o. Failed to cover the direct effects and any indirect, secondary, cumulative, short, medium
and long-term, permanent and temporary, positive and negative effects of the project
p. The forecasting methods used to assess the effects on the environment
q. A description of the measures envisaged to prevent any significant adverse effects
r.

A description of the measures envisaged to reduce any significant adverse effects

s. A description of the measures envisaged to prevent any significant adverse effects

44. The Request by the Developer to haver the application dealt with under Directive
2014/52/EU amending the EIA Directive 2011/92/EU leaves members of the Public at a
disadvantage in that it creates two differing frameworks for the evaluation of the
project and puts members of th e Public at a disadvantage if they cannot determine
which framework will be used, BEFORE they make submissions. The Bord must clarify
which framework it will use and allow additional submissions should it adopt the new
amended Directive.
45. The Bord is requested to conduct an Oral Hearing to allow an opportunity to seek
clarifications and further detail from the Developer, on the nature of the project, on the
EIS Submitted, and on the Planning Documentation Submitted.

46. A question arises as to the extent of the consent provided by landowners, as to whether
that consent allows the construction and operation of structures on their lands that
would be:
I. A source of noise nuisance that would cause nuisance to others, by way of
interrupting sleep or preventing sleep at any time of the168 hours in a week.
II.
Cause or contribute to the diminution of adjoining or proximate lands or buildings in
terms of current open market value or future development value.
47. A question arises as to whether the property interest to be conveyed from the Current

Site Owners to the Wind Farm Development Company and its heirs, assignees, and
successors, is sufficient to allow any conditions the Bord might see fit to impose such as

40

would maximise the amount of CO2 and GHGs avoided by the development by way of
attaching planning conditions that would prohibit livestock rearing for meat across the
702 hectares outlined in red on the Site. In order to maximise the CO2 saving from the
Development it would be necessary to stop the generation of Green House Gases
(GHGs)on the site. There is little sense in paying subsidies to avoid CO2 and paying
subsidies to produce CO2 on the same 702 hectares. The likely output of GHGs in terms
of CO2 equivalent for a tonne of Beef is 19 tonnes of CO2. With beef outputs of 1
tonnes per hectare being realistic levels of output. Ireland produces 564,000 tonnes of
Beef annually a major source of non ETS emissions. The earlier part of this submission
details the very substantial level of emissions arising from Beef production on the 702hectare site, and the degree to which those Farming related emissions severely limit any
CO2 saving derived from the development. The Bord are reminded that this project has
been already designated as Strategic Infrastructure, all be it provisionally, and that that
designation can be overturned as per the Judgement of Judge Costello in Callaghan v An
Bord Pleanla. It is obvious that Infrastructure that is deemed to be of Strategic
Importance, must be compatible with the Objects of Resource Efficiency, Energy
Efficiency, as set out in the Energy Efficiency Directive, the Waste Framework Directive,
and that it is compatible with Recital 44 of the Renewable Energy Directive ( The
coherence between the objectives of this Directive and the Communitys other environmental
legislation should be ensured. In particular, during the assessment, planning or licensing
procedures for renewable energy installations, Member States should take account of all
Community environmental legislation and the contribution made by renewable energy sources
towards meeting environmental and climate change objectives, in particular when compared
to non-renewable energy installations.) http://eur-lex.europa.eu/legalcontent/EN/ALL/?uri=CELEX:32009L0028

48. The Developer has never set out this Development as having the capacity to provide renewable
electricity at lower cost than competitors, or to provide electricity at the open market price without State
Aid support. It seems reasonable having regard to EU Energy Policy, EU Competitive Market Policy to use
such criteria in in the evaluation of what constitutes Strategic Infrastructure. The Developer has
continuously claimed the imperative of securing access to the REFIT Scheme and linked such access to
the viability of the proposed wind farm. It is clear that this proposed windfarm has no strategic or
competitive advantage or competitive potential over alternative sites. In fact with one of the lowest wind
speeds of any site ever developed for wind power in Ireland that is not surprising. The Bord are referred
to the Communication from the Commission Guidelines on State aid for environmental protection
and energy 2014-2020 The Commission now place great strategic advantage in getting renewables off
State Aid and this would seem to be a key criteria for any Infrastructure that might be designated as SID.
http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52014XC0628(01)

49. The nature of the development proposed having regard to the quantity of wind power nameplate
capacity already connected to the All Ireland Electrcity System, is such that much other infrastructure is
necessary by way of Grid Reinforcements and the expansion of Interconnectors to export surpluses in
order to allow the proposed turbines to bring their electricity production to market and to avoid the full
potential production on which claims of CO2 saving are based to be achieved. Because these pieces of
infrastructure are not identified no the limitations of the benefits of the project arising should they not
be built, it is not possible to evaluate the project for the purposes of th e EIA Directive. The OGrianna
Decision indicates the way our law is evolving to take account not just the construction of Infrastructure
but also how well it might function in service. Any step beyond OGrianna that would look at the

41
functionality of Infrastructure in service, that is still so dependent on State Aid would deliver great
public benefit and assist in securing the objectives of EU Energy, Environmental, Economic, and Strategic
Policy.

From Eirgrid All Island Ten Year Transmission Forecast Statement 2015 section 3.10

http://www.eirgridgroup.com/site-files/library/EirGrid/2015-TYTFS-Complete_Approved.pdf
The load frequency curves above indicate the distribution of electricity demand on the Island of
Ireland. Of the 950MW of Interconnection with the UK only 750MW actually function. Negative
pricing on electricity exports is a feature of Electricity Exports from Ireland. Because Wind
Power is not Dispatchable meaning that it cannot be relied upon to be available it much more
difficult to contract to sell it. Where electricity is exported without the Renewable Credit
described in the Renewable Energy Directive it would have a lower value which may well yield a
negative price to the Single Electricity Market Operator SEMO. Only 55% of the electricity
feeding into the Grid can be derived form a combination of wind power and 750MW of
interconnectors.

42

The nature of the annual demand profile is further described by the figure above
From Eirgrid All Island Ten Year Transmission Forecast Statement 2015 section 3.2
http://www.eirgridgroup.com/site-files/library/EirGrid/2015-TYTFS-Complete_Approved.pdf
Peak demand will typically occur in the coldest weather often when the wind does not blow at
all.

See page 35 http://www.eirgridgroup.com/sitefiles/library/EirGrid/Generation_Capacity_Statement_20162025_FINAL.pdf

It is obvious that if 7250MW of wind power is to be connected to the All Ireland Grid much of
the capacity will be redundant for very substantial periods of the year.
There is no evidence that intermittent renewable electricity can be exported in large quantities
over large periods of the year other than at a loss.
FIGURE 10 COMPARISON OF AVERAGE WHOLESALE BASELOAD ELECTRICITY PRICES, FIRST QUARTER
OF 2016

43

Quarterly Report on European Electricity Prices EU Commission see page 13

https://ec.europa.eu/energy/sites/ener/files/documents/quarterly_report_on_european_elect
ricity_markets_q4_2015-q1_2016.pdf
HVDC Interconnectors have substantial capital costs and the return on investment must be
substantial in order to attract capital to fund their development. The Moyle Interconnector was
developed to have a capacity of 450MW but only 250MW actually works. An Interconnector
must recover its costs and make a profit on the electricity transmits in a year. However Wind
Power is not available for all of the year and average capacity factors achieved in Ireland is only
31%. What would the capacity factor be on additional Interconnectors?
Are we to maintain 8000MW of thermal generation plant in Ireland and degrade their market
with interconnectors?
If Nuclear Power is to be developed why would anyone want to use wind turbines use wind
turbines with nuclear power?
o cost that must be based on th
50. Project splitting is contemplated as the Grid Connection P230 is a 120MW MEC (Maximum
Export Capacity) grid connection. See September 2016 Report

44

http://www.eirgridgroup.com/site-files/library/EirGrid/Contracted-TSO-Wind-Farms-1th-Sept2016.pdf
Bord Pleanla granted the applicant SID Status for a 65-85MW windfarm that has a 120MW
MEC Grid connection in May 2016. Currently The Commission for Energy Regulation require
that Currently a generator must both:
pass Capacity Tests including Capacity Test B (i.e. generating at least 95% of its MEC for
a duration of 30 minutes); and
receive an Operational Certificate;
see page 2
http://www.cer.ie/docs/001101/CER16165%20MEC%20Security%20Policy%20Amendments.pd
f
Currently a generator must pass Capacity Test B within twelve months of their Energisation
Date (ED) for Transmission, or Connection Agreement Effective Date (CAED) for Distribution
projects, or the MEC Security Regime 2 measures will be applied. The SOs propose that for large
wind farms, which may have longer construction periods, the Capacity Testing Period allowed
for generators to achieve Capacity Test B be extended from the current twelve months, to
twelve months plus an additional one month for every 10MW of MEC (or part thereof) >
50MW.
The Bord found that the Castletownmoor Windfarm would be Strategic Infrastructure despite
the fact that the proposal for 68.75 to 85MW of was based on hoarding massive amounts of
Transmission Capacity contrary to CER Policy.
The hoarding of Grid connection and Grid Capacity prevents alternatives being pursued by
other developers, while allowing a Developer to pursue project splitting.
This has major implications in term so fComplying with the EIA Directive.
While OGrianna involved a lack of Grid connection this case involved approval to hoard Grid
Capacity. Capacity Hoarding and Project Splitting go hand in hand. The normal arrangement for
a windfarm is for the windfarm nameplate capacity to exceed the MEC by 105% to 120%. In this
situation it was granted SID status with the Name Plate Capacity of the Windfarm being as
little as 57.3% of the MEC
5.0 Assessment
th

5.1 Compliance with the 7 Schedule

Having regard to the nature and scale of the proposed facility comprising a total of 25 no.
turbines and having a total power output of up to 85 MW), it is my opinion that the proposed
development comes within the scope of class 1 of the Seventh Schedule of the Strategic
Infrastructure Act, 2006 (as amended) being An installation for the harnessing of wind power for
energy production (a wind farm) with more than 25 turbines or having a total output greater
than 50 megawatts.

The Bord are requested to de-designate the Castletownmoor Windfarm as Strategic

Infrastructure.
51. During the SID Consultation Stage the Bords Inspector stated in his report that:
5.2.1 The prospective applicant states that the proposed development would be of strategic
economic importance to the State. The information provided to support this statement is limited
and it would appear that it is partially based on the principle of national renewable energy policy

45
and that the State would be liable for fines and financial penalties in the event that renewable
energy targets are not met. The prospective applicant provided some information to the Board
during the pre-application consultation regarding research by SEAI that has suggested that the
cost to Ireland of missing the 2020 targets could be between 70-140 million per percentage
point shortfall. On this basis the proposed development could reduce potential fines for the State
by up to 23 million.
The Bord accepted the proposition that 25 Wind turbines could save the State 23 million in
Fines. At the same time the Bord were denying members of the Public an opportunity to
comment on the very same application.
The Applicant has claimed a CO2 saving of up to 115, 000 tonnes per year with a 460 gram of
CO2 per kWh of wind power saving for an 85MW Development of 25 x 3.4 MW Turbines.
(1352.94 tonnes CO2 per MWh)
The applicant had previously claimed a 180,000 tonne CO2 saving in the Emlagh application for
46 x 3.5MW turbines or 161 MW of Windpower (1118 tonnes per MW)
115,000 tonnes of CO2 @ a CO2 intensity of 460 grams per kWh or ( 0.46 tonnes of CO2 per
MWh) equates to 115,000 tonnes / 0.46 tonnes of CO2 per MWh = 250,000 MWh of Electricity
per year (convenient round number)
250,000MWh @ 11.630 MWh per toe (tonne of oil equivalent) equates to 21,496 toe
Energy consumption in 2014 was 13,270,000 toe
Irelands overall Renewable target is 16%
16% of the 2014 consumption is 2,123,200
1% of the 2014 consumption is 132,700toe
21496toe is 16.2% of 1% of the renewable target
0.162% of 70 million is 11.34 million.

EU Policy & The Energy & Climate Package

The 2020 package is a set of binding legislation to ensure the EU meets its climate and
energy targets for the year 2020.

The package sets three key targets:

20% cut in greenhouse gas emissions (from 1990 levels)
20% of EU energy from renewables
20% improvement in energy efficiency
The targets were set by EU leaders in 2007 and enacted in legislation in 2009. They are
also headline targets of the Europe 2020 strategy for smart, sustainable and inclusive
growth.
The EU is taking action in several areas to meet the targets.

The Targets are underpinned by the following directives:

The Renewable Energy Directive 2009/28/EC

http://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:32009L0028

The Energy Efficiency Directive 2012/27/EU

http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1399375464230&uri=CELEX:32012L0027

Directive 2008/98/EC on waste (Waste Framework Directive) (which includes waste heat)
http://ec.europa.eu/environment/waste/framework/

46

The EU emissions trading system is the EU's key tool for cutting greenhouse gas emissions from
large-scale facilities in the power and industry sectors, as well as the aviation sector.
The ETS covers around 45% of the EU's greenhouse gas emissions.

National emission reduction targets

This covers the sectors not in the ETS accounting for some 55% of total EU emissions such
as:

housing
agriculture
waste

transport (excluding aviation).

EU countries have taken on binding annual targets until 2020 for cutting emissions in these
sectors (compared to 2005), under the "Effort-sharing decision"

Recital 44 of 2009/28/EC requires The coherence between the objectives of this Directive and the
Communitys other environmental legislation should be ensured. In particular, during the assessment,
planning or licensing procedures for renewable energy installations, Member States should take account
of all Community environmental legislation and the contribution made by renewable energy sources
towards meeting environmental and climate change objectives, in particular when compared to nonrenewable energy installations
Increasing Wind power penetration requires the progressive degrading of the back up thermal power
plant. This is contrary to the objectives of the Waste framework Directive of prevention, recovery of
waste heat and reuse. It is aslo against the objectives of the Energy Efficiency Directive of increasing
efficiency of electricity generation, reusing waste heat for CHP or tri generation, and taking a holistic
approach to the directives to reduce energy use and improve Resource Efficiency as articulated in
Recital 3 of Directive 2014/52/EU
(3) It is necessary to amend Directive 2011/92/EU in order to strengthen the quality of the
environmental impact assessment procedure, align that procedure with the principles of smart
regulation and enhance coherence and synergies with other Union legislation and policies, as well
as strategies and policies developed by Member States in areas of national competence.

47

The applicant envisages an approach to the Energy Problem that is

centered on wind power generation
Article 5(4) of the TFEU says that: Under the principle of proportionality, the content and form
of Union action shall not exceed what is necessary to achieve the objectives of the Treaties.
This means the worst case senario would be no more expensive than the cheapest way of
meeting the targets. It would be much cheaper than doling out tax reliefs and subsidies to
Wind Power Developers. Such Subsidies are 15 year commitments.
The EU does have the power to impose fines on any Member State
Articles 260 and 261 of the current EU Treaty on the Functioning of the European Union (TFEU)
allow the Commission to bring a complaint to the European Court of Justice (ECJ) that a
Member State has failed to comply with a Regulation or transpose a Directive and the ECJ can
levy a fine on that Member State.
In particular, Article 260(3) says:
When the Commission brings a case before the Court pursuant to Article 258 on the grounds
that the Member State concerned has failed to fulfil its obligation to notify measures
transposing a directive adopted under a legislative procedure, it may, when it deems
appropriate, specify the amount of the lump sum or penalty payment to be paid by the Member
State concerned which it considers appropriate in the circumstances.
If the Court finds that there is an infringement it may impose a lump sum or penalty payment on
the Member State concerned not exceeding the amount specified by the Commission. The
payment obligation shall take effect on the date set by the Court in its judgment.

Imported Electricity is essentially CO2 free for Carbon accounting while CO2 belching coal and Peat are
maintaining a substantial presence in Electricity Generation. Gas power electricity is dominant but the
generation is split equally between low efficiency OCGT Turbines at 30 odd % and high efficiency CCGT
turbines that can achieve efficiency of up to 58%.

48

OCGT Efficiencies under variable load

http://irishenergyblog.blogspot.ie/2015/05/cost-benefit-analysis-obligations-for.html

http://www.seai.ie/Publications/Statistics_Publications/Energy_in_Ireland/Energy_in_Ireland_Key_Stati
stics/Energy-in-Ireland-Key-Statistics-2015.pdf
In terms of growing consumption primary energy the Transport sector stands out. Transport and
Residential account for 62.5% of emissions. No Solution is possible without tackeling this sector
The Renewable Energy Directive has been recently revised by Directive (EU) 2015/1513
Article 2 of that directive allows a 250% bonus on any electricity that is applied to the transport
sector.
http://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX%3A32015L1513 http://www.greenemotionproject.eu/

49

http://www.seai.ie/Publications/Statistics_Publications/Energy_in_Ireland/Energy_in_Ireland_Key_Stati
stics/Energy-in-Ireland-Key-Statistics-2015.pdf

Greenhouse Gas Emission Projections to 2020 An update EPA

Update March 2016

https://www.epa.ie/pubs/reports/air/airemissions/2020_GHG_Projections_2016_Bulletin.pdf
Key trends
Irelands non-ETS emissions are projected to be 6% and 11% below 2005 levels in 2020 under the With
Measures and With Additional Measures scenarios, respectively. The target for Ireland is a 20%
reduction.
Ireland is projected to exceed its annual binding limits in 2016 and 2017 under the With Measures and
With Additional Measures scenarios, respectively (Figure 1).

50

Agricultural emissions will grow 7% and Transport emissions by 16% between 2014 & 2020

This document has earlier challenged the proposition that Wind Power CO2 savings are
460grams per kWh and made the case that a glut of wind power will require massive levels of
curtailment.

52. The proposed wind farm is located adjacent to the Blackwater Corridor & Rathkenny Hills
both characterised in the Development Plan as of Very High Value.

51

52. The Developer cannot have it both ways! You cannot have trees to screen wind turbines
and have open terrain suitable for low wind shear to maximise power production and
reduce turbulence. The Proposed Site will have high wind shear due to the extensive
trees.

53. The EU Machinery Directive 2006/42/EC Applies to Wind Turbines

Article 4 Market surveillance
1. Member States shall take all appropriate measures to
ensure that machinery may be placed on the market and/or put into service only if it satisfies
the relevant provisions of this Directive and does not endanger the health and safety of persons
and, where appropriate, domestic animals or property, when properly installed and maintained
and used for its intended purpose or under conditions which can reasonably be
foreseen.
The Directive could be interpreted as requiring that the noise emissions are minimised by
locating the machines (wind turbines) at such locations as would minimise noise impact on
people.

52
2. Member States shall take all appropriate measures to ensure that partly completed
machinery can be placed on the market only if it satisfies the relevant provisions of this
Directive.
3. Member States shall institute or appoint the competent authorities to monitor the conformity
of machinery and partly completed machinery with the provisions set out in paragraphs 1 and 2.
4. Member States shall define the tasks, organisation and powers of the competent authorities
referred to in paragraph 3 and shall notify the Commission and other Member States thereof
and also of any subsequent amendment.
Annex 1 1.5.8. Noise
Machinery must be designed and constructed in such a way that risks resulting from the
emission of airborne noise are reduced to the lowest level, taking account of technical progress
and the availability of means of reducing noise, in particular at source.
[Comment The Directive would apply the biggest set back in Europe from housing to the
machinery (wind turbines) in all jurisdictions since the largest setback or largest distance in
the EU would provide the lowest level of noise.]
54. Why were there no records on wind speed or wind direction submitted with the application
such as a wind rose, which is a key piece of data for the design and evaluation of any wind
farm design?
55. The Castletownmoor Site Location has the lowest Average Wind Speed in Meath(SEAI 2013
Wind Atlas.

53

56. The Wind Industry dispute that wind turbines cause adverse health impacts. Several
Studies show varied output of noise from wind turbines that exceed forecasts. Turbines
can emit noise levels at 5,10, 15, and 20 dBA over prevailing background noise levels.
Regulatory regimes are based on averaged noise levels while short peaks cause impacts.
The Bord are requested to consider the literature below in Making their Assessment.

Industrial Wind Turbines and Health:

Wind Turbines Can Harm Humans if too close to Residents1
A summary of some of the peer reviewed articles and conference papers, abstracts and other
citations, regarding impairment of health in general and relating to industrial wind turbines2
Compiled by Carmen Krogh, BScPharm
April 20153
PEER REVIEWED
Ambrose, Stephen E.; Rand, Robert W.; and Krogh, Carmen M. E.
Wind Turbine Acoustic Investigation: Infrasound and Low-Frequency Noise
A Case Study DOI: 10.1177/0270467612455734
Bulletin of Science Technology & Society published online 17 August 2012
http://bst.sagepub.com/content/early/2012/07/30/0270467612455734
Abstract
Wind turbines produce sound that is capable of disturbing local residents and is reported to cause
annoyance, sleep disturbance, and other health-related impacts. An acoustical study was conducted to
investigate the presence of infrasonic and low-frequency noise emissions from wind turbines located
in Falmouth, Massachusetts, USA. During the study, the investigating acousticians experienced
adverse health effects consistent with those reported by some Falmouth residents. The authors
conclude that wind turbine acoustic energy was found to be greater than or uniquely distinguishable
from the ambient background levels and capable of exceeding human detection thresholds. The
authors emphasize the need for epidemiological and laboratory research by health professionals and
acousticians concerned with public health and well-being to develop effective and precautionary
setback distances for industrial wind turbines that protect residents from wind turbine sound.
______________________________________________________________
Arra I, Lynn H, Barker K, et al. (2014-05-23 11:51:41 UTC) Systematic Review 2013:
Association between Wind Turbines and Human Distress. Cureus 6(5): e183.
doi:10.7759/cureus.183
http://www.cureus.com/articles/2457-systematic-review-2013-association-between-windturbinesand-human-distress
Abstract
Background and Objectives: The proximity of wind turbines to residential areas has been associated
with a higher level of complaints compared to the general population. The study objective was to
search the literature investigating whether an association between wind turbines and human distress
exists.
Methods: A systematic search of the following databases (EMBASE, PubMed, OvidMedline,
PsycINFO, The Cochrane Library, SIGLE, and Scirus) and screening for duplication led to the
1 Excerpted

from Case Nos.: 10-121/10-122 Erickson v. Director, Ministry of the Environment

Environmental Review Tribunal, Decision, p 207 This case has successfully shown the debate should not be simplified to
one about whether wind turbines can cause harm to humans. The evidence presented to the Tribunal demonstrates that they
can, if facilities are placed too close to residents. The debate has now evolved to one of degree.
2 This summary focuses on references 2010 to April 2015 associated with risks to health. References are not intended to be
exhaustive.
3 Any errors or omissions are unintended

identification of 154 studies. Abstract and full article reviews of these studies led to the identification

54
of 18 studies that were eligible for inclusion as they examined the association of wind turbines and
human distress published in peer-review journals in English between 2003-2013. Outcome measures
including First Author, Year of Publication, Journal Name, Country of Study, Study Design, Sample
Size, Response Rate, Level of Evidence, Level of Potential Bias, and Outcome Measures of Study
were captured for all studies. After data extraction, each study was analyzed to identify the two
primary outcomes: Quality of Study and Conclusion of Study Effect.
Results: All peer-reviewed studies captured in our review found an association between wind
turbines and human distress. These studies had levels of evidence of four and five. Two studies
showed a dose-response relationship between distance from wind turbines and distress, and none of
them concluded no association.
Conclusions: In this review, we have demonstrated the presence of reasonable evidence (Level Four
and Five) that an association exists between wind turbines and distress in humans. The existence of a
dose-response relationship (between distance from wind turbines and distress) and the consistency of
association across studies found in the scientific literature argues for the credibility of this association.
Future research in this area is warranted as to whether or not a causal relationship exists.
______________________________________________________________
Bakker RH, E. Pedersen E, van den Berg, GP, Stewart RE, Lok W, Bouma J
Impact of wind turbine sound on annoyance, self-reported sleep disturbance and
psychological distress
Science of the Total Environment 425 (2012) 4251
doi:10.1016/j.scitotenv.2012.03.005
Abstract
Purpose of the research: The present government in the Netherlands intends to realize a substantial
growth of wind energy before 2020, both onshore and offshore. Wind turbines, when positioned in
the neighborhood of residents may cause visual annoyance and noise annoyance. Studies on other
environmental sound sources, such as railway, road traffic, industry and aircraft noise show that
(long-term) exposure to sound can have negative effects other than annoyance from noise. This study
aims to elucidate the relation between exposure to the sound of wind turbines and annoyance,
selfreported
sleep disturbance and psychological distress of people that live in their vicinity. Data were
gathered by questionnaire that was sent by mail to a representative sample of residents of the
Netherlands living in the vicinity of wind turbines
Principal results: A doseresponse relationship was found between immission levels of wind turbine
sound and self reported noise annoyance. Sound exposure was also related to sleep disturbance and
psychological distress among those who reported that they could hear the sound, however not directly
but with noise annoyance acting as a mediator. Respondents living in areas with other background
sounds were less affected than respondents in quiet areas.
Major conclusions: People living in the vicinity of wind turbines are at risk of being annoyed by the
noise, an adverse effect in itself. Noise annoyance in turn could lead to sleep disturbance and
psychological distress. No direct effects of wind turbine noise on sleep disturbance or psychological
stress has been demonstrated, which means that residents, who do not hear the sound, or do not feel
disturbed, are not adversely affected.
__________________________________________________________________
Basner M, Brink M, Bristow A, de Kluizenaar Y, Finegold L, Hong J, Janssen SA, Klaeboe R,
Leroux T, Liebl A, Matsui T, Schwela D, Sliwinska-Kowalska M, Srqvist P. ICBEN review of
research on the biological effects of noise 2011-2014. Noise Health [serial online] 2015 [cited
2015 Mar 23 ];17:57-82 Available from:
http://www.noiseandhealth.org/text.asp?2015/17/75/57/153373

3
Abstract: The mandate of the International Commission on Biological Effects of Noise
(ICBEN) is to promote a high level of scientific research concerning all aspects of noiseinduced
effects on human beings and animals. In this review, ICBEN team chairs and cochairs
summarize relevant findings, publications, developments, and policies related to the
biological effects of noise, with a focus on the period 2011-2014 and for the following topics:

55

Noise-induced hearing loss; nonauditory effects of noise; effects of noise on performance and
behavior; effects of noise on sleep; community response to noise; and interactions with other
agents and contextual factors. Occupational settings and transport have been identified as the
most prominent sources of noise that affect health. These reviews demonstrate that noise is a
prevalent and often underestimated threat for both auditory and nonauditory health and that
strategies for the prevention of noise and its associated negative health consequences are
needed to promote public health.
______________________________________________________________
Bernert RA, and Joiner TE
Sleep disturbances and suicide risk: A review of the literature.
Neuropsychiatr Dis Treat. 2007 December; 3(6): 735743. PMCID: PMC2656315
http://www.ncbi.nlm.nih.gov/pmc/articles/PMC2656315/
Abstract
A growing body of research indicates that sleep disturbances are associated with suicidal ideation and
behaviors. This article provides a critical review of the extant literature on sleep and suicidality and
addresses shared underlying neurobiological factors, biological and social zeitgebers, treatment
implications, and future directions for research. Findings indicate that suicidal ideation and behaviors
are closely associated with sleep complaints, and in some cases, this association exists above and
beyond depression. Several cross-sectional investigations indicate a unique association between
nightmares and suicidal ideation, whereas the relationship between insomnia and suicidality requires
further study. Underlying neurobiological factors may, in part, account for the relationship between
sleep and suicide. Serotonergic neurotransmission appears to play a critical role in both sleep and
suicide. Finally, it remains unclear whether or not sleep-oriented interventions may reduce risk for
suicidal behaviors. Unlike other suicide risk factors, sleep complaints may be particularly amenable to
treatment. As a warning sign, disturbances in sleep may thus be especially useful to research and may
serve as an important clinical target for future suicide intervention efforts.
_____________________________________________________________________
Bronzaft, Arline L.
The Noise from Wind Turbines: Potential Adverse Impacts on Children's Well-Being
Bulletin of Science Technology & Society 2011 31: 256, DOI: 10.1177/0270467611412548.
http://bst.sagepub.com/content/31/4/291
Abstract
Research linking loud sounds to hearing loss in youngsters is now widespread, resulting in the
issuance of warnings to protect childrens hearing. However, studies attesting to the adverse effects of
intrusive sounds and noise on childrens overall mental and physical health and well-being have not
received similar attention. This, despite the fact that many studies have demonstrated that intrusive
noises such as those from passing road traffic, nearby rail systems, and overhead aircraft can
adversely affect childrens cardiovascular system, memory, language development, and learning
acquisition. While some schools in the United States have received funds to abate intrusive aircraft
noise, for example, many schools still expose children to noises from passing traffic and overhead
aircraft. Discussion focuses on the harmful effects of noise on children, what has to be done to
remedy the situation, and the need for action to lessen the impacts of noise from all sources.

Furthermore, based on our knowledge of the harmful effects of noise on childrens health and the
growing body of evidence to suggest the potential harmful effects of industrial wind turbine noise, it
is strongly urged that further studies be conducted on the impacts of industrial wind turbines on their
health, as well as the health of their parents, before forging ahead in siting industrial wind turbines.
____________________________________________________________________
Enbom H and Enbom IM, Infrasound from wind turbines: An overlooked health hazard,
Lkartidningen, vol. 110 (2013), pp. 1388-89.
Abstract:
Infrasound from wind turbines affects the inner ear and is a potential health risk for people with
migraine or other type of central nervous system. The authors maintain that the legal framework for
the creation of new wind turbines should be revised, taking into account this fact. Previous scientific

56
studies on wind turbines and infrasound have been contradictory. They have therefore not been
sufficiently credible when planning a framework for the establishment of wind turbines. In recent
years, however, a new insight has emerged on the central nervous system, providing a better
understanding of migraine, fibromyalgia and other chronic pain syndromes and some cases of tinnitus
and dizziness. This understanding is also important for understanding how infrasound from wind
turbines can affect health. Several studies have found that living near wind turbines often create
severe sleep disturbance and depression. They have also found an increased incidence of dizziness,
tinnitus, hyperacusis, headache, increased activation of the autonomic nervous system, etc.
______________________________________________________________
Farboud, A.; Crunkhorn, R.; and Trinidade, A.
Wind turbine syndrome: fact or fiction? Review Article
The Journal of Laryngology & Otology, 1 of 5.
JLO (1984) Limited, 2013, doi:10.1017/S0022215112002964
Abstract
Objective: Symptoms, including tinnitus, ear pain and vertigo, have been reported following
exposure to wind turbine noise. This review addresses the effects of infrasound and low frequency
noise and questions the existence of wind turbine syndrome.
Design: This review is based on a search for articles published within the last 10 years, conducted
using the PubMed database and Google Scholar search engine, which included in their title or abstract
the terms wind turbine, infrasound or low frequency noise.
Results: There is evidence that infrasound has a physiological effect on the ear. Until this effect is
fully understood, it is impossible to conclude that wind turbine noise does not cause any of the
symptoms described. However, many believe that these symptoms are related largely to the stress
caused by unwanted noise exposure.
Conclusion: There is some evidence of symptoms in patients exposed to wind turbine noise. The
effects of infrasound require further investigation.
There is ample evidence of symptoms arising in individuals exposed to wind turbine noise. Some
researchers maintain that the effects of wind turbine syndrome are clearly just examples of the well
known stress effects of exposure to noise, as displayed by a small proportion of the population.
However, there is an increasing body of evidence suggesting that infrasound and low frequency noise
have physiological effects on the ear. Until these effects are fully understood, it is impossible to state
conclusively that exposure to wind turbine noise does not cause any of the symptoms described. The
effects of infrasound and low frequency noise require further investigation.

______________________________________________________________
Harrison, John P.
Wind Turbine Noise
Bulletin of Science Technology & Society 2011 31: 256, DOI:
10.1177/0270467611412549
http://bst.sagepub.com/content/31/4/256
Abstract
Following an introduction to noise and noise regulation of wind turbines, the problem of adverse
health effects of turbine noise is discussed. This is attributed to the characteristics of turbine noise and
deficiencies in the regulation of this noise. Both onshore and offshore wind farms are discussed.
________________________________________________________________________
Havas, Magda and Colling, David
Wind Turbines Make Waves:
Why Some Residents Near Wind Turbines Become Ill
Bulletin of Science Technology & Society 2011 31: 414. DOI: 0.1177/0270467611417852
http://bst.sagepub.com/content/31/5/369
Abstract
People who live near wind turbines complain of symptoms that include some combination of the
following: difficulty sleeping, fatigue, depression, irritability, aggressiveness, cognitive dysfunction,
chest pain/pressure, headaches, joint pain, skin irritations, nausea, dizziness, tinnitus, and stress.

57
These symptoms have been attributed to the pressure (sound) waves that wind turbines generate in the
form of noise and infrasound. However, wind turbines also generate electromagnetic waves in the
form of poor power quality (dirty electricity) and ground current, and these can adversely affect those
who are electrically hypersensitive. Indeed, the symptoms mentioned above are consistent with
electrohypersensitivity. Sensitivity to both sound and electromagnetic waves differs among
individuals and may explain why not everyone in the same home experiences similar effects. Ways to
mitigate the adverse health effects of wind turbines are presented.
________________________________________________________________________
Hanning, Christopher D. and Evans, Alun
Editorial: Wind turbine noise
British Medical Journal, BM J2 012;344 doi: 10.1136/ bmj.e1527 (8 March 2012)
www.bmj.com
Except from BMJ web site:
Seems to affect health adversely and an independent review of evidence is needed.
The evidence for adequate sleep as a prerequisite for human health, particularly child health, is
overwhelming. Governments have recently paid much attention to the effects of environmental noise
on sleep duration and quality, and to how to reduce such noise. However, governments have also
imposed noise from industrial wind turbines on large swathes of peaceful countryside.
The impact of road, rail, and aircraft noise on sleep and daytime functioning (sleepiness and cognitive
function) is well established. Shortly after wind turbines began to be erected close to housing,
complaints emerged of adverse effects on health. Sleep disturbance was the main complaint. Such
reports have been dismissed as being subjective and anecdotal, but experts contend that the quantity,
consistency, and ubiquity of the complaints constitute epidemiological evidence of a strong link
between wind turbine noise, ill health, and disruption of sleep.

________________________________________________________________________
Horner, Brett; Jeffery Roy D.; and Krogh, Carmen M. E.
Literature Reviews on Wind Turbines and Health : Are They Enough?
Bulletin of Science Technology & Society 2011 31: 399.
DOI: 10.1177/0270467611421849
http://bst.sagepub.com/content/31/5/399
Abstract
Industrial wind turbines (IWTs) are a new source of community noise to which relatively few people
have yet been exposed. IWTs are being erected at a rapid pace in proximity to human habitation.
Some people report experiencing adverse health effects as a result of living in the environs of IWTs.
In order to address public concerns and assess the plausibility of reported adverse health effects, a
number of literature reviews have been commissioned by various organizations. This article explores
some of the recent literature reviews on IWTs and adverse health effects. It considers the
completeness, accuracy, and objectivity of their contents and conclusions. While some of the
literature reviews provide a balanced assessment and draw reasonable scientific conclusions, others
should not be relied on to make informed decisions. The article concludes that human health research
is required to develop authoritative guidelines for the siting of IWTs in order to protect the health and
welfare of exposed individuals.
_____________________________________________________________________
James, Richard R.
Wind Turbine Infra and Low-Frequency Sound: Warnings Signs That Were Not Heard
DOI: 10.1177/0270467611421845
Bulletin of Science Technology & Society published online 15 December 2011
http://bst.sagepub.com/content/early/2011/11/07/0270467611421845
Abstract
Industrial wind turbines are frequently thought of as benign. However, the literature is reporting
adverse health effects associated with the implementation of industrial-scale wind developments. This
article explores the historical evidence about what was known regarding infra and low-frequency
sound from wind turbines and other noise sources during the period from the 1970s through the end

58
of the 1990s. This exploration has been accomplished through references, personal interviews and
communications, and other available documentation. The application of past knowledge could
improve the current siting of industrial wind turbines and avoid potential risks to health.
_____________________________________________________________________
Jeffery, Roy D.; Krogh, Carmen; and Horner, Brett
Industrial wind turbines and adverse health effects
Can J Rural Med 2014;19(1)
http://www.ncbi.nlm.nih.gov/pubmed/24398354
Health is one of the fundamental rights of every human being. Some people exposed to IWTs
experience negative effects to their physical, mental and social well-being. There is sufficient
evidence to support the hypothesis of Colby and colleagues that documented symptoms can result
from annoyance to audible IWTs. Amplitude modulation of IWTs, audible LFN, and tonal, impulse
and nighttime noise can contribute to annoyance and other effects on health. In addition, there is
emerging evidence that suggests inaudible LFN or infrasound from IWTs may result in negative
health effects.
Further research is required to clarify the exact role that sound characteristics, visual impacts,

stray voltage and socioeconomic impacts of IWTs may have on human health. As more IWTs are
installed, rural physicians are likely to be presented with increasing numbers of patients who are
adversely affected. Based on current knowledge, we expect that, at typical setback distances and
sound pressure levels of IWTs in Ontario, a nontrivial percentage of exposed people will be adversely
affected. Trade-offs of health for perceived benefit in alternate forms of energy can be prevented if
setback distances and noise limits are developed using established noise management techniques. In
addition to providing care for affected patients, rural physicians have a responsibility to advance
understanding and to help inform IWT regulations that will protect the physical, mental and social
well-being of patients.
_____________________________________________________________________
Jeffery, Roy D.; Krogh, Carmen; and Horner, Brett
Adverse health effects of industrial wind turbines
Can Fam Physician 2013; 59: 473-475 (Commentary)
http://www.ncbi.nlm.nih.gov/pmc/articles/PMC3653647
Conclusion
Industrial wind turbines can harm human health if sited too close to residents. Harm can be avoided if
IWTs are situated at an appropriate distance from humans. Owing to the lack of adequately protective
siting guidelines, people exposed to IWTs can be expected to present to their family physicians in
increasing numbers. The documented symptoms are usually stress disordertype diseases acting via
indirect pathways and can represent serious harm to human health. Family physicians are in a position
to effectively recognize the ailments and provide an empathetic response. In addition, their
contributions to clinical studies are urgently needed to clarify the relationship between IWT exposure
and human health and to inform regulations that will protect physical, mental, and social well-being.
_____________________________________________________________________
Jeffery, Roy D.; Krogh, Carmen; and Horner, Brett
Adverse health effects of industrial wind turbines
Can Fam Physician 2013; 59: 923-925 (Letter to the Editor)
http://www.ncbi.nlm.nih.gov/pmc/articles/PMC3771715/
Conclusion
Mr Barnard writes that health effects are related to the negative attitude of the individual exposed to
IWTs. Some researchers have found that the IWTs were initially welcomed into communities for their
perceived economic or environmental benefits. The reported adverse impacts were unexpected. The
2011 Ontario Real Estate Association Form 220 (Seller Property Information Statement) requires
disclosure of environmental issues when selling residential property, including toxic waste, soil
contamination, landfills, and wind turbines planned for the immediate area. The adverse health effects
of audible and inaudible noise are substantial. Their effects are underestimated and underappreciated
by some. We are guided by the references and the desire to safeguard the health and wellbeing of

59
those living in the environs of IWTs. Harm can be avoided by placing IWTs at a protective distance
from residents. The acknowledgment that health effects occur in some is an important step toward
achieving this goal.
________________________________________________________________________
Krogh, Carmen M.E.
Industrial Wind Turbine Development and Loss of Social Justice?
Bulletin of Science Technology & Society 2011 31: 321, DOI: 10.1177/0270467611412550,
http://bst.sagepub.com/content/31/4/321

Abstract
This article explores the loss of social justice reported by individuals living in the environs of
industrial wind turbines (IWTs). References indicate that some individuals residing in proximity to
IWT facilities experience adverse health effects. These adverse health effects are severe enough that
some families have abandoned their homes. Individuals report they welcomed IWTs into their
community and the negative consequences were unexpected. Expressions of grief are exacerbated by
the emotional and physical toll of individuals symptoms, loss of enjoyment of homes and property,
disturbed living conditions, financial loss, and the lack of societys recognition of their situation. The
author has investigated the reported loss of social justice through a review of literature, personal
interviews with, and communications from, those reporting adverse health effects. The authors
intention is to create awareness that loss of social justice is being associated with IWT development.
This loss of justice arises from a number of factors, including the lack of fair process, the loss of
rights, and associated disempowerment. These societal themes require further investigation. Research
by health professionals and social scientists is urgently needed to address the health and social
impacts of IWTs operating near family homes.
_____________________________________________________________
Krogh, Carmen M.E.; Gillis, Lorrie; Kouwen, Nicholas; and Aramini, Jeffery
WindVOiCe, a Self-Reporting Survey: Adverse Health Effects, Industrial Wind Turbines, and
the Need for Vigilance Monitoring
Bulletin of Science Technology & Society 2011 31: 334,
DOI: 10.1177/0270467611412551,
http://bst.sagepub.com/content/31/4/334
Abstract
Industrial wind turbines have been operating in many parts of the globe. Anecdotal reports of
perceived adverse health effects relating to industrial wind turbines have been published in the media
and on the Internet. Based on these reports, indications were that some residents perceived they were
experiencing adverse health effects. The purpose of the WindVOiCe health survey was to provide
vigilance monitoring for those wishing to report their perceived adverse health effects. This article
discusses the results of a self reporting health survey regarding perceived adverse health effects
associated with industrial wind turbines.
_____________________________________________________________
Robert Y McMurtry and Carmen ME Krogh
Diagnostic criteria for adverse health effects in the environs of wind turbines
DOI: 10.1177/2054270414554048
JRSM Open
http://shr.sagepub.com/content/5/10/2054270414554048

PMID: 25383200 [PubMed] PMCID: PMC4221978

http://www.ncbi.nlm.nih.gov/pubmed/?term=Diagnostic+criteria+for+adverse+health+
effects+in+the+environs+of+wind+turbines

Summary
In an effort to address climate change, governments have pursued policies that seek to reduce
greenhouse gases. Alternative energy, including wind power, has been proposed by some as the
preferred approach. Few would debate the need to reduce air pollution, but the means of achieving
this reduction is important not only for efficiency but also for health protection. The topic of adverse
health effects in the environs of industrial wind turbines (AHE/IWT) has proven to be controversial

60
and can present physicians with challenges regarding the management of an exposure to IWT. Rural
physicians in particular must be aware of the possibility of people presenting to their practices

with a variety of sometimes confusing complaints. An earlier version of the diagnostic criteria for
AHE/IWT was published in August 2011. A revised case definition and a model for a study to
establish a confirmed diagnosis is proposed.
_____________________________________________________________
McMurtry, Robert Y.
Toward a Case Definition of Adverse Health Effects in the Environs of Industrial Wind
Turbines: Facilitating a Clinical Diagnosis
Bulletin of Science Technology & Society 2011 31: 316, DOI: 10.1177/0270467611415075,
http://bst.sagepub.com/content/31/4/316
Abstract
Internationally, there are reports of adverse health effects (AHE) in the environs of industrial wind
turbines (IWT). There was multidisciplinary confirmation of the key characteristics of the AHE at the
first international symposium on AHE/IWT. The symptoms being reported are consistent
internationally and are characterized by crossover findings or a predictable appearance of signs and
symptoms present with exposure to IWT sound energy and amelioration when the exposure ceases.
There is also a revealed preference of victims to seek restoration away from their homes. This article
identifies the need to create a case definition to establish a clinical diagnosis. A case definition is
proposed that identifies the sine qua non diagnostic criteria for a diagnosis of adverse health effects in
the environs of industrial wind turbines. Possible, probable, and confirmed diagnoses are detailed.
The goal is to foster the adoption of a common case definition that will facilitate future research
efforts.
___________________________________________________________________________

Kugler K,Wiegrebe L,Grothe B, Kssl M, Grkov R, Krause E, Drexl M.

Low-frequency sound affects active micromechanics in the human inner ear.
R. Soc. open sci. 1: 140166.
http://dx.doi.org/10.1098/rsos.140166
Conclusion
The results of this study clearly indicate that there is a pronounced discrepancy between the
unobtrusive perception of LF sound, reflected in their low sensation levels and the
physiological responses of the cochlea following the LF sound exposure. To the best of our
knowledge, perception has been the only measure available in humans to assess inner ear
responses to very LF sound, but, as the current data show, severely underestimates cochlear
and, especially OHC, sensitivity. Direct quantifications of inner ear active amplification, as
measured in this study, are much better suited to assess the risk potential of LF sound.
_____________________________________________________________________
Mller-Levet CS; Archer SN; Bucca, G; Laing EE; Slak A; Kabiljo R; Lo JCY.; Santhi N; von
Schantz M; Smith CP.; and Derk-Jan D
Effects of insufficient sleep on circadian rhythmicity and expression
amplitude of the human blood transcriptome
Published online before print February 25, 2013, doi:10.1073/pnas.1217154110
PNAS (Proceedings of the National Academy of Sciences)
February 25, 2013 201217154 http://www.pnas.org/content/early/2013/02/20/1217154110
Abstract (Excerpt)
Insufficient sleep and circadian rhythm disruption are associated with negative health outcomes,
including obesity, cardiovascular disease, and cognitive impairment, but the mechanisms involved

10

remain largely unexplored Biological processes affected included chromatin modification,

geneexpression
regulation, macromolecular metabolism, and inflammatory, immune and stress responses.
Thus, insufficient sleep affects the human blood transcriptome, disrupts its circadian regulation, and

61
intensifies the effects of acute total sleep deprivation. The identified biological processes may be
involved with the negative effects of sleep loss on health, and highlight the interrelatedness of sleep
homeostasis, circadian rhythmicity, and metabolism.
______________________________________________________
Mller, Henrik and Pedersen, Christian Sejer
Low-frequency noise from large wind turbines
Section of Acoustics, Aalborg University, Denmark, Acoustical Society of America [DOI:
10.1121/1.3543957] J. Acoust. Soc. Am. 129 (6), June 2011 PACS number(s): 43.50.Rq,
43.28.Hr, 43.50.Cb, 43.50.Sr [ADP] Pages: 37273744
Abstract
As wind turbines get larger, worries have emerged that the turbine noise would move down in
frequency and that the low-frequency noise would cause annoyance for the neighbors. The
noise emission from 48 wind turbines with nominal electric power up to 3.6 MW is analyzed and
discussed. The relative amount of low-frequency noise is higher for large turbines (2.33.6 MW) than
for small turbines ( 2 MW), and the difference is statistically significant. The difference can also be
expressed as a downward shift of the spectrum of approximately one-third of an octave. A further
shift of similar size is suggested for future turbines in the 10-MW range. Due to the air absorption, the
higher low-frequency content becomes even more pronounced, when sound pressure levels in
relevant neighbor distances are considered. Even when A-weighted levels are considered, a
substantial part of the noise is at low frequencies, and for several of the investigated large turbines,
the one-third-octave band with the highest level is at or below 250 Hz. It is thus beyond any doubt
that the low-frequency part of the spectrum plays an important role in the noise at the neighbors.
___________________________________________________________________________
Munzel T, Goril T, Babisch W, Basner M, Cardiovascular effects of environmental
noise exposure. European Heart Journal (2014) 35, 829836
doi:10.1093/eurheartj/ehu030
Summary
The role of noise as an environmental pollutant and its impact on health are being increasingly
recognized. Beyond its effects on the auditory system, noise causes annoyance and disturbs sleep, and
it impairs cognitive performance. Furthermore, evidence from epidemiologic studies demonstrates
that environmental noise is associated with an increased incidence of arterial hypertension,
myocardial infarction, and stroke. Both observational and experimental studies indicate that in
particular night-time noise can cause disruptions of sleep structure, vegetative arousals (e.g. increases
of blood pressure and heart rate) and increases in stress hormone levels and oxidative stress, which in
turn may result in endothelial dysfunction and arterial hypertension. This review focuses on the
cardiovascular consequences of environmental noise exposure and stresses the importance of noise
mitigation strategies for public health.
Conclusions
Taken together, the present review provides evidence that noise not only causes annoyance, sleep
disturbance, or reductions in quality of life, but also contributes to a higher prevalence of the most
important cardiovascular risk factor arterial hypertension and the incidence of cardiovascular
diseases. The evidence supporting such contention is based on an established rationale supported by
experimental laboratory and observational field studies, and a number of epidemiological studies.
Meta-analyses have been carried out to derive exposureresponse relationships that can be used for

11

quantitative health impact assessments. Noise-induced sleep disturbance constitutes an important

mechanism on the pathway from chronic noise exposure to the development of adverse health effects.
The results call for more initiatives aimed at reducing environmental noise exposure levels to promote
cardiovascular and public health. Recent studies indicate that peoples attitude and awareness in
particular towards aircraft noise has changed over the years. Noise mitigation policies have to
consider the medical implications of environmental noise exposure. Noise mitigation strategies to
improve public health include noise reduction at the source, active noise control (e.g. noise optimized
take-off and approach procedures), optimized traffic operations (including traffic curfews), better
infrastructural planning, better sound insulation in situations where other options are not feasible, and

62
adequate limit values.
_________________________________________________________________________
Nissenbaum, Michael A.; Aramini, Jeffery J.; and Hanning, Christopher D.
Effects of industrial wind turbine noise on sleep and health
Noise & Health, September-October 2012, Volume 14, p243
www.noiseandhealth.org
Abstract
Industrial wind turbines (IWTs) are a new source of noise in previously quiet rural environments.
Environmental noise is a public health concern, of which sleep disruption is a major factor. To
compare sleep and general health outcomes between participants living close to IWTs and those
living further away from them, participants living between 375 and 1400 m (n= 38) and 3.3 and 6.6
km (n = 41) from IWTs were enrolled in a stratified cross-sectional study involving two rural sites.
Validated questionnaires were used to collect information on sleep quality (Pittsburgh Sleep Quality
Index PSQI), daytime sleepiness (Epworth Sleepiness Score ESS), and general health
(SF36v2), together with psychiatric disorders, attitude, and demographics. Descriptive and
multivariate analyses were performed to investigate the effect of the main exposure variable of
interest (distance to the nearest IWT) on various health outcome measures. Participants living within
1.4 km of an IWT had worse sleep, were sleepier during the day, and had worse SF36 Mental
Component Scores compared to those living further than 1.4 km away. Significant dose-response
relationships between PSQI, ESS, SF36 Mental Component Score, and log-distance to the nearest
IWT were identified after controlling for gender, age, and household clustering. The adverse event
reports of sleep disturbance and ill health by those living close to IWTs are supported.
_________________________________________________________________________
Persinger, Michael A.
Infrasound, human health, and adaptation:
an integrative overview of recondite hazards in a complex environment
Nat Hazards
DOI 10.1007/s11069-013-0827-3
This article is published with open access at www.Springerlink.com
Conclusion
Living systems, including the human species, have evolved within a natural environment
whose properties are complex but not intractable to measurement and understanding. Although the
partitioning of the formal description of natural phenomena by different scientific disciplines may
have satisfied the conditions of human cognition, the subsequent traditions may have obscured the
essential relationships between human adaptation and the natural environment that is optimally
discerned through true interdisciplinary approaches.
Human beings can be described as both mechanical and energetic organisms. There are

12

multiple sources of stimuli that exhibit energetic equivalents whose values in turn converge with
those essential for the function of the cell, the organ, and the organism. The frequencies that have
been defined as infrasound, from natural, manufactured, and as yet unknown sources, have the
capacity to resonate with the human body. This review of the scientific literature and the quantitative
illustrations derived from the systematic application of known principles may facilitate the acquisition
of the precision required to differentiate between natural hazards and natural benefits rather than
depending primarily upon political and social agendas.
_____________________________________________________________________
Phillips, Carl V. Properly Interpreting the Epidemiologic Evidence About the Health Effects of
Industrial Wind Turbines on Nearby Residents
Bulletin of Science Technology & Society 2011 31: 303, DOI: 10.1177/0270467611412554,
http://bst.sagepub.com/content/31/4/303
Abstract
There is overwhelming evidence that wind turbines cause serious health problems in nearby residents,
usually stress-disorder type diseases, at a nontrivial rate. The bulk of the evidence takes the form of
thousands of adverse event reports. There is also a small amount of systematically gathered data. The

63
adverse event reports provide compelling evidence of the seriousness of the problems and of
causation in this case because of their volume, the ease of observing exposure and outcome incidence,
and case-crossover data. Proponents of turbines have sought to deny these problems by making a
collection of contradictory claims including that the evidence does not count, the outcomes are not
real diseases, the outcomes are the victims own fault, and that acoustical models cannot explain
why there are health problems so the problems must not exist. These claims appeared to have swayed
many nonexpert observers, though they are easily debunked. Moreover, though the failure of models
to explain the observed problems does not deny the problems, it does mean that we do not know
what, other than kilometers of distance, could sufficiently mitigate the effects. There has been no
policy analysis that justifies imposing these effects on local residents. The attempts to deny the
evidence cannot be seen as honest scientific disagreement and represent either gross incompetence or
intentional bias.
______________________________________________________________
Punch, Jerry; James, Rick; and Pabst, Dan
Wind-Turbine Noise
What Audiologists Should Know
Audiology Today, July/August 2010
Conclusion
Our purpose in this article has been to provide audiologists with a better understanding of the types of
noise generated by wind turbines, some basic considerations underlying sound-level measurements of
wind-turbine noise, and the adverse health effects on people who live near these turbines. In future
years, we expect that audiologists will be called upon to make noise measurements in communities
that have acquired wind turbines, or are considering them. Some of us, along with members of the
medical profession, will be asked to provide legal testimony regarding our opinions on the effects of
such noise on people. Many of us will likely see clinical patients who are experiencing some of the
adverse health effects described in this article. As a professional community, audiologists should
become involved not only in making these measurements to corroborate the complaints of residents
living near wind-turbine projects but also in developing and shaping siting guidelines that minimize
the potentially adverse health effects of the noise and vibration they generate. In these ways, we can
promote public health interests without opposing the use of wind turbines as a desirable and viable
alternative energy source.

13

_____________________________________________________________________
Rand, Robert W.; Ambrose, Stephen E.; and Krogh, Carmen M. E.
Occupational Health and Industrial Wind Turbines: A Case Study
Bulletin of Science Technology & Society 2011 31: 359DOI: 10.1177/0270467611417849
http://bst.sagepub.com/content/31/5/359
Abstract
Industrial wind turbines (IWTs) are being installed at a fast pace globally. Researchers, medical
practitioners, and media have reported adverse health effects resulting from living in the environs of
IWTs. While there have been some anecdotal reports from technicians and other workers who work
in the environs of IWTs, little is known about the occupational health sector. The purpose of this case
study is to raise awareness about the potential for adverse health effects occurring among workers.
The authors propose that there is a need for research regarding occupational worker exposure relating
to IWTs.
_____________________________________________________________________
Salt, Alec N. and Hullar, T.E.
Responses of the ear to low frequency sounds, infrasound and wind turbines.
Department of Otolaryngology, Washington University School of Medicine, St. Louis, MO,
63110, USA.
Hearing Research 2010 Sep 1; 268(1-2):12-21. Epub 2010 Jun 16
Abstract
Infrasonic sounds are generated internally in the body (by respiration, heartbeat, coughing, etc) and
by external sources, such as air conditioning systems, inside vehicles, some industrial processes and,

64
now becoming increasingly prevalent, wind turbines. It is widely assumed that infrasound presented
at an amplitude below what is audible has no influence on the ear. In this review, we consider
possible ways that low frequency sounds, at levels that may or may not be heard, could influence the
function of the ear. The inner ear has elaborate mechanisms to attenuate low frequency sound
components before they are transmitted to the brain. The auditory portion of the ear, the cochlea, has
two types of sensory cells, inner hair cells (IHC) and outer hair cells (OHC), of which the IHC are
coupled to the afferent fibers that transmit "hearing" to the brain. The sensory stereocilia ("hairs") on
the IHC are "fluid coupled" to mechanical stimuli, so their responses depend on stimulus velocity and
their sensitivity decreases as sound frequency is lowered. In contrast, the OHC are directly coupled to
mechanical stimuli, so their input remains greater than for IHC at low frequencies. At very low
frequencies the OHC are stimulated by sounds at levels below those that are heard. Although the hair
cells in other sensory structures such as the saccule may be tuned to infrasonic frequencies, auditory
stimulus coupling to these structures is inefficient so that they are unlikely to be influenced by
airborne infrasound. Structures that are involved in endolymph volume regulation are also known to
be influenced by infrasound, but their sensitivity is also thought to be low. There are, however,
abnormal states in which the ear becomes hypersensitive to infrasound. In most cases, the inner ear's
responses to infrasound can be considered normal, but they could be associated with unfamiliar
sensations or subtle changes in physiology. This raises the possibility that exposure to the infrasound
component of wind turbine noise could influence the physiology of the ear.
_______________________________________________________________________
Salt, Alec N. and Kaltenbach, James A.
Infrasound From Wind Turbines Could Affect Humans
Bulletin of Science Technology & Society 2011 31: 296,
DOI: 10.1177/0270467611412555
http://bst.sagepub.com/content/31/4/296

14

Abstract
Wind turbines generate low-frequency sounds that affect the ear. The ear is superficially similar to a
microphone, converting mechanical sound waves into electrical signals, but does this by complex
physiologic processes. Serious misconceptions about low-frequency sound and the ear have resulted
from a failure to consider in detail how the ear works. Although the cells that provide hearing are
insensitive to infrasound, other sensory cells in the ear are much more sensitive, which can be
demonstrated by electrical recordings. Responses to infrasound reach the brain through pathways that
do not involve conscious hearing but instead may produce sensations of fullness, pressure or tinnitus,
or have no sensation. Activation of subconscious pathways by infrasound could disturb sleep. Based
on our current knowledge of how the ear works, it is quite possible that low-frequency sounds at the
levels generated by wind turbines could affect those living nearby.
_______________________________________________________________________

Schomer PD, Erdreich J, Pamidighantam KP, and Boyle JH, February 2015)
A theory to explain some physiological effects of the infrasonic emissions at some wind
farm sites J. Acoust. Soc. Am. 137 (3), March 13561365. 2015
http://dx.doi.org/10.1121/1.4913775
For at least four decades, there have been reports in scientific literature of people
experiencing motion sickness-like symptoms attributed to low-frequency sound and
infrasound. In the last several years, there have been an increasing number of such reports
with respect to wind turbines; this corresponds to wind turbines becoming more prevalent. A
study in Shirley, WI, has led to interesting findings that include: (1) To induce major effects,
it appears that the source must be at a very low frequency, about 0.8 Hz and below with
maximum effects at about 0.2 Hz; (2) the largest, newest wind turbines are moving down in
frequency into this range; (3) the symptoms of motion sickness and wind turbine acoustic
emissions sickness are very similar; (4) and it appears that the same organs in the inner ear,
the otoliths may be central to both conditions. Given that the same organs may produce the
same symptoms, one explanation is that the wind turbine acoustic emissions may, in fact,

65

induce motion sickness in those prone to this affliction.

______________________________________________________________________
Seltenrich, Nate
Wind Turbines A Different Breed of Noise?
Environmental Health Perspectives, volume 122 | number 1 | January 2014
Looking Long Term
The gold standard for proving causality of an exposure is the randomized clinical trial. But when it
comes to testing the health effects of noise exposure on humans, such a study design is likely to be
not only impractical and difficult to implement, but also unethical.
The next-best evidence would come from longitudinal field research, many researchers agree, such as
long-term studies that assess the health of a community before a turbine project is ever proposed and
then continue to follow up during operation. Lercher notes that some effects of chronic noise
exposure such as elevated blood pressure could take one or two decades to manifest at significant
levels.
Most of the studies performed to date around both transportation and wind-farm sources have been
cross-sectional, which makes it impossible to assess causality. Thats because investigators cannot
establish whether the potential cause precedes the potential effect. Lercher stresses that cross15
sectional studies purporting to demonstrate a relationship between noise exposures and health effects
may be averaging out potential effects that are only visible in some subgroupse.g., those with
certain medical risk factors, or those exposed to the noise for longer than others.
______________________________________________________________________
Shain, Martin, Public Health Ethics, Legitimacy, and the Challenges of Industrial Wind
Turbines: The Case of Ontario, CanadaBulletin of Science Technology & Society, 2011 31: 256
DOI: 10.1177/0270467611412552,
http://bst.sagepub.com/content/31/4/346
Abstract
While industrial wind turbines (IWTs) clearly raise issues concerning threats to the health of a few in
contrast to claimed health benefits to many, the trade-off has not been fully considered in a public
health framework. This article reviews public health ethics justifications for the licensing and
installation of IWTs. It concludes that the current methods used by government to evaluate licensing
applications for IWTs do not meet most public health ethical criteria. Furthermore, these methods are
contrary to widely held fundamental principles of administrative law and governmental legitimacy. A
set of decision-making principles are suggested to address this situation that are derived from existing
and emerging legal principles in Canada and elsewhere. These include the Precautionary Principle,
the Least Impactful Means (Proportionality) Test, and the Neighbor Principle.
_________________________________________________________________________
Shepherd, Daniel; Welch, David; Dirks, Kim N.; and McBride, David (March 2013)
Do Quiet Areas Afford Greater Health-Related Quality of Life than Noisy Areas? International
Journal of Environmental Research and Public Health, ISSN 1660-4601
http://www.mdpi.com/1660-4601/10/4/1284
Abstract: People typically choose to live in quiet areas in order to safeguard their health and
wellbeing. However, the benefits of living in quiet areas are relatively understudied compared to the
burdens associated with living in noisy areas. Additionally, research is increasingly focusing on the
relationship between the human response to noise and measures of health and wellbeing,
complementing traditional dose-response approaches, and further elucidating the impact of noise and
health by incorporating human factors as mediators and moderators. To further explore the benefits of
living in quiet areas, we compared the results of health-related quality of life (HRQOL) questionnaire
datasets collected from households in localities differentiated by their soundscapes and population
density: noisy city, quiet city, quiet rural, and noisy rural. The dose-response relationships between
noise annoyance and HRQOL measures indicated an inverse relationship between the two.
Additionally, quiet areas were found to have higher mean HRQOL domain scores than noisy areas.
This research further supports the protection of quiet locales and ongoing noise abatement in noisy
areas.
_________________________________________________________________________

66
Shepherd D, Hanning C, Thorne B. Noise: Windfarms (2012) Published in the
Encyclopedia of Environmental Management (peer review panel for all articles)
DOI: 10.1081/E-EEM-120047802
Abstract:
Windfarms consist of clusters of wind turbines, which, when placed in populated areas, are associated
with intrusive and unwanted sound. A relatively new noise source; wind turbine noise has
characteristics sufficiently different from other, more extensively studied, noise sources to suggest
that preexisting noise standards are not appropriate. Though research into the human impacts of wind
turbine noise has appeared only in the last decade and in small quantity, the data suggest that, for
equivalent exposures, wind turbine noise is more annoying than road or aviation noise. Furthermore,
the particular characteristics of wind turbine noise may be likely to cause sleep disruption. As with
other impulsive noise sources, time-aggregated noise metrics have limited utility in protecting public
health, and a cluster of metrics should be used in order to estimate potential threat. At this time,
however, the quantity and quality of research are insufficient to effectively describe the relationship
between wind turbine noise and health, and so legislation should apply the precautionary principle or
conservative criteria when assessing proposed windfarm developments.
___________________________________________________________________________
Shepherd, Daniel and Billington, Rex
Mitigating the Acoustic Impacts of Modern Technologies: Acoustic, Health, and Psychosocial
Factors Informing Wind Farm Placement
Bulletin of Science Technology & Society 2011 31: 389
DOI: 10.1177/0270467611417841
http://bst.sagepub.com/content/31/5/389
Abstract
Wind turbine noise is annoying and has been linked to increased levels of psychological distress,
stress, difficulty falling asleep and sleep interruption. For these reasons, there is a need for
competently designed noise standards to safeguard community health and well-being. The authors
identify key considerations for the development of wind turbine noise standards, which emphasize a
more social and humanistic approach to the assessment of new energy technologies in society.
___________________________________________________________________________
Shepherd, Daniel; McBride, David; Welch; Dirks, Kim N.; and Hill Erin M.
Evaluating the impact of wind turbine noise on health related quality of life
Noise & Health, September-October 2011, 13:54,333-9
DOI: 10.4103/1463-1741.85502
www.noiseandhealth.org
Abstract
We report a cross-sectional study comparing the health-related quality of life (HRQOL) of individuals
residing in the proximity of a wind farm to those residing in a demographically matched area
sufficiently displaced from wind turbines. The study employed a nonequivalent comparison group
posttest-only design. Self-administered questionnaires, which included the brief version of the World
Health Organization quality of life scale, were delivered to residents in two adjacent areas in
semirural New Zealand. Participants were also asked to identify annoying noises, indicate their
degree of noise sensitivity, and rate amenity. Statistically significant differences were noted in some
HRQOL domain scores, with residents living within 2 km of a turbine installation reporting lower
overall quality of life, physical quality of life, and environmental quality of life. Those exposed to
turbine noise also reported significantly lower sleep quality, and rated their environment as less
restful. Our data suggest that wind farm noise can negatively impact facets of HRQOL.
Acknowledgements: We are grateful to our colleagues and others whose reviews substantially
improved the manuscript. We are especially grateful for the thorough review undertaken by Professor
Rex Billington, who as the WHO Director of Mental Health in the 1990s oversaw the development of
the WHOs program into quality of life, health and the environment.

17

______________________________________________________________________
Thorne R, and Shepherd D, Quiet as an Environmental Value: A Contrast between Two

67
Legislative Approaches. Int. J. Environ. Res. Public Health 2013, 10
Abstract
This paper examines the concept of quiet as an environmental value in terms of amenity and
wellbeing from a legislative context. Critical review of two pieces of environmental legislation from
Australia and New Zealand forms the basis of the paper. The Australian legislation is Queenslands
Environmental Protection Act, and the New Zealand legislation is that nations Resource
Management Act. Quiet is part of the psychoacoustic continuum between a tranquil and an intrusively
noisy sound environment. As such, quiet possesses intrinsic value in terms of overall sound within the
environment (soundscape) and to individuals and communities. In both pieces of legislation,
guidance, either directly or indirectly, is given to maximum sound levels to describe the acoustic
environment. Only in Queensland is wellbeing and amenity described as environmental values, while
in the New Zealand approach, amenity is identified as the core value to defend, but guidance is not
well established. Wellbeing can be related to degrees of quietness and the absence of intrusive noise,
the character of sound within an environment (soundscape), as well as the overall level of sound.
The quality of life experienced by individuals is related to that persons physical and mental health,
sense of amenity and wellbeing. These characteristics can be described in terms of subjective and
objective measures, though legislation does not always acknowledge the subjective.
______________________________________________________________________
Thorne, Bob
The Problems With ''Noise Numbers'' for Wind Farm Noise Assessment
Bulletin of Science Technology & Society 2011 31: 262
DOI: 10.1177/0270467611412557,
http://bst.sagepub.com/content/31/4/262
Abstract
Human perception responds primarily to sound character rather than sound level. Wind farms are
unique sound sources and exhibit special audible and inaudible characteristics that can be described
as modulating sound or as a tonal complex. Wind farm compliance measures based on a specified
noise number alone will fail to address problems with noise nuisance. The character of wind farm
sound, noise emissions from wind farms, noise prediction at residences, and systemic failures in
assessment processes are examined. Human perception of wind farm sound is compared with noise
assessment measures and complaint histories. The adverse effects on health of persons susceptible to
noise from wind farms are examined and a hypothesis, the concept of heightened noise zones
(pressure variations), as a marker for cause and effect is advanced. A sound level of LAeq 32 dB
outside a residence and above an individuals threshold of hearing inside the home are identified as
markers for serious adverse health effects affecting susceptible individuals. The article is referenced
to the authors research, measurements, and observations at different wind farms in New Zealand and
Victoria, Australia.
OTHER:

Cooper S,The Results of an Acoustical Testing Program Cape Bridgewater Wind Farm,
Prepared for Energy Pacific (Vic) Pty, Ltd Link to report and appendices:
http://www.pacifichydro.com.au/english/our-communities/communities/capebridgewateracoustic-study-report/?language=en
18
Steven Cooper, acoustician from Australia. Conducted a study and as a result of the study
design, the exhaustive infrasound (typically inaudible) measurements, the detailed diaries
kept by the families, and the developers (Pacific Hydro) cooperation, this study has
advanced the understanding of the role of infrasound and human responses associated with
industrial wind turbines.
The link to report and appendices:
http://www.pacifichydro.com.au/english/our-communities/communities/capebridgewateracoustic-study-report/?language=en
Reviews of the study by members of the international community can be viewed at the
Waubra Foundation web site:

68

http://waubrafoundation.org.au/2015/steven-coopers-cape-bridgewater-acousticresearchcommissioned-by-pacific-hydro-released/
______________________________________________________________

Howell G, Shubat D, and Krogh C., (January 2015) Autism and the effect of
introducing a new noise source into quiet rural communities: risk factor from industrial
wind power generation. Western University: From the Selected Works of Grace L
Howell Faculty of Education Western University
http://works.bepress.com/grace_howell/1

Background and Objectives

Some individuals with Autism Spectrum Disorders (ASD) may react negatively to noise including
low-frequency noise, infrasound, vibration and other environmental emissions. There are specific
concerns in the Province of Ontario, Canada, related to the exposure of people with autism to the
environmental noise and infrasound produced by an additional noise source, in this case from the
introduction of industrial-scale wind turbines into quiet rural communities. The objective of this
report is to explore the potential for effects of exposure to a new noise source on this specific and
vulnerable population. There is a significant research gap regarding the impact of the introduction of
industrial-scale power generation from wind into rural communities and on children with ASD. The
additional noise and low-frequency sound produced by the wind turbines may add to the burden of
environmental noise that the ASD population is already coping with, including exposures at home and
at school. Front-line professionals such as educators and health care workers need to be aware of this
possibility.
______________________________________________________________
Salt AN and Lichtenhan JT, How Does Wind Turbine Noise Affect People? Acoustics
Today. A publication of the Acoustical Society of America.
Volume 10: Issue One: Winter 2014
Conclusions and Concerns
We have described multiple ways in which infrasound and low-frequency sounds could affect the ear
and give rise to the symptoms that some people living near wind turbines report. If, in time, the
symptoms of those living near the turbines are demonstrated to have a physiological basis, it will
become apparent that the years of assertions from the wind industrys acousticians that what you
cant hear cant affect you or that symptoms are psychosomatic or a nocebo effect was a great
injustice. The current highly-polarized situation has arisen because our understanding of the
consequences of long-term infrasound stimulation remains at a very primitive level. Based on well
established principles of the physiology of the ear and how it responds to very low-frequency sounds,
there is ample justification to take this problem more seriously than it has been to date. There are
many important scientific issues that can only be resolved through careful and objective research.
Although infrasound generation in the laboratory is technically difficult, some research groups are
already in the process of designing the required equipment to perform controlled experiments in
humans.
One area of concern is the role that some acousticians and societies of acousticians have played. The
primary role of acousticians should be to protect and serve society from negative influences of noise
exposure. In the case of wind turbine noise, it appears that many have been failing in that role. For
years, they have sheltered behind the mantra, now shown to be false, that has been presented
repeatedly in many forms such as What you cant hear, cant affect you.; If you cannot hear a
sound you cannot perceive it in other ways and it does not affect you.; Infrasound from wind
turbines is below the audible threshold and of no consequence.; Infrasound is negligible from this
type of turbine.; I can state categorically that there is no significant infrasound from current designs
of wind turbines. All of these statements assume that hearing, derived from low-frequency insensitive
IHC responses, is the only mechanism by which low frequency sound can affect the
body. We know this assumption is false and blame its origin on a lack of detailed understanding of
the physiology of the ear.
Another concern that must be dealt with is the development of wind turbine noise measurements that
have clinical relevance. The use of A-weighting must be reassessed as it is based on insensitive, IHC
mediated hearing and grossly misrepresents inner ear stimulation generated by the noise. In the

69
scientific domain, A-weighting sound measurements would be unacceptable when many elements of
the ear exhibit a higher sensitivity than hearing. The wind industry should be held to the same high
standards. Full-spectrum monitoring, which has been adopted in some reports, is essential.
In the coming years, as we experiment to better understand the effects of prolonged low-frequency
sound on humans, it will be possible to reassess the roles played by acousticians and professional
groups who partner with the wind industry. Given the present evidence, it seems risky at best to
continue the current gamble that infrasound stimulation of the ear stays confined to the ear and has no
other effects on the body. For this to be true, all the mechanisms we have outlined (low frequency
induced amplitude modulation, low frequency sound-induced endolymph volume changes, infrasound
stimulation of type II afferent nerves, infrasound exacerbation of noise-induced damage and direct
infrasound stimulation of vestibular organs) would have to be insignificant. We know this is highly
unlikely and we anticipate novel findings in the coming years that will influence the debate.
From our perspective, based on our knowledge of the physiology of the ear, we agree with the insight
of Nancy Timmerman that the time has come to acknowledge the problem and work to eliminate it.
______________________________________________________________

A Cooperative Measurement Survey and Analysis of Low Frequency and Infrasound at

the Shirley Wind Farm in Brown County, Wisconsin Report Number 122412-1 Issued:
December 24, 2012
Excerpted
20
The Brown County Board of Health continued with its investigation and on October 14, 2014
Dr. Jay Tibbetts, member of the Brown County Board of Health states that the Brown Co.
Board of Health's meeting of 10-14-14 unanimously approved a motion to declare the Shirley
Wind turbines to be a human health hazard. [Ref: Brown County Board of Health,
Proceedings of the Board of Health Meeting, Tuesday, October 14, 2014, 5:00 PM]

___________________________________________________
Editor: Bob Thorne,
Noise Measurement Services Pty Ltd Wind Farm Noise Review April 2013
PREAMBLE
There is significant body of peer-reviewed research readily available in the public forum to
substantiate the potential for serious to moderate adverse health effects to individuals due to wind
farm activity noise while living in their residences and while working on their farms near large-scale
wind farms or large turbines. Adverse health effects can arise from extreme psychological stress from
environmental noise, particularly low frequency noise with symptoms of sleep disturbance, headache,
tinnitus, ear pressure, dizziness, vertigo, nausea, visual blurring, tachycardia, irritability, problems
with concentration and memory, and panic attack episodes associated with such sensations when
awake or asleep.
The hypothesis from this Review is that serious harm to health occurs when a susceptible individual
is so beset by the noise in question that he or she suffers recurring sleep disturbance, anxiety and
stress.
Research for the Review suggests that 5% to 10% of the individuals living in the vicinity of a large
wind farm will experience serious harm to their health. The observed markers for serious health
effects are
(a) wind farm noise level of LAeq 32 dB or more outside the residence and
(b) wind farm noise is heard or is perceptible (felt) at levels above the individuals threshold
of hearing inside the home
Meteorological conditions, wind turbine spacing and associated wake and turbulence effects, vortex
effects, wind shear, turbine synchronicity, tower height, blade length, and power settings all
contribute to sound levels heard or perceived at residences. Wind farms are unique sound sources and
exhibit special audible characteristics that can be described as modulating sound or as a tonal
complex. Current noise prediction models are simplistic, have a high degree of uncertainty, and do
not make allowance for these significant variables. Compliance monitoring must therefore include

21

70
continuous real-time measurement of characteristics such as modulating sound in order to determine
the perceptible effects of audible sound and inaudible infrasound.
The Review contains references to the NMS research, measurements, and observations at different
wind farms in New Zealand and Australia. All NMS research including the study methodologies are
peer reviewed. Such work is commercial-in-confdence to NMS and of a confidential nature to the
participants. No datasets, apart from those presented in this Review, are disclosed or publicly
available.

Canadian Medical Association Journal (CMAJ) Blog

Carmen Krogh, BScPharm and R Y McMurtry, M.D., F.R.C.S.(C), F.A.C.S., Health Canada
and Wind Turbines: Too little too late? CMAJ November 28, 2014
http://cmajblogs.com/health-canada-and-wind-turbines-too-little-too-late/

CONFERENCE PAPERS
Ambrose, Stephen E.; Rand, Robert W.; and Krogh, Carmen M. E.
Falmouth, Massachusetts wind turbine infrasound and
low frequency noise measurements
Invited paper presented at Inter-noise 2012 New York City, NY
Abstract
Falmouth, Massachusetts has experienced non-predicted adverse acoustic and health impacts from an
industrial wind turbine (IWT) sited close to neighbors. The public response from this quiet rural area
has been very vocal for a majority of homeowners living within 3000-ft. Complaints have ranged
from the unexpectedly loud with constant fluctuations and the non-audible pressure fluctuations
causing a real loss of public health and well-being. Early research indicates that both the IHC and
OHC functions of the ear receive stimulation during moderate to strong wind speeds. This research
presents a challenge to noise control and health professionals to determine the causal factors for the
adverse public health impacts. This case study will present sound level and analyzed measurement
data obtained while living in a house 1700-ft from an operating IWT during moderate to strong hub
height wind speeds. There was a strong correlation with wind speed, power output and health
symptoms.
______________________________________________________________
Andreucci, Federica; Atzori, Delio; Baratta, Claudio; Betti, Rinaldo; Carriero, Antonella et al.
Correlation between people perception of noise from large wind turbines
and measured noise levels
Paper presented at the Wind Turbine Noise conference 2013, August 28 to 30, Denver,
Colorado, USA
Summary
ISPRA, in collaboration with the Sapienza University of Rome, have carried out a study on
perceptions, opinions and attitudes of citizens in relation to the planning, implementation and working
of wind power systems. The study area has involved four municipalities in the South of Italy,
including the municipality of SantAgata di Puglia (Foggia). The research activities have been
divided in two main phases: a first phase of empirical research based on interviews, and the second
phase of survey by means questionnaire distribution to a sample citizens in the above mentioned
municipalities.

______________________________________________________________
Horner, Brett; Krogh, Carmen ME; and Jeffery, Roy D.
Audit report: literature reviews on wind turbine noise and health
Paper presented at the Wind Turbine Noise conference 2013, August 28 to 30, Denver,
Colorado, USA
Abstract
Wind turbines can harm humans if placed too close to residents. Health effects are most frequently
associated with wind turbine noise. At typical setbacks and sound levels in Ontario Canada a nontrivial
percentage those exposed to wind turbine sound will be highly annoyed which can be expected
to contribute to stress related health impacts. In recent years a number of literature reviews have been

71
produced which purport to examine the plausibility of wind turbine noise induced health effects.
Some of these literature reviews have been sponsored by governments or organizations with policies
which support wind energy development. Members of and/or consultants for the wind energy industry
frequently cite literature reviews to support the claim wind turbine noise does not pose a risk to
human health. Various literature reviews on wind turbines and health are examined using standard
audit procedures. Findings reveal that while some literature reviews provide a balanced assessment
other literature reviews contain errors of omission and/or commission and lack completeness,
accuracy, and objectivity. These findings support the conclusion that a rigorous audit should be
conducted before literature reviews on wind turbine noise and health can be relied upon.
______________________________________________________________

Krogh CME Noise and Childrens Risk Factors including Industrial Wind Energy
Facilities, Paper presented at the he 7th International Symposium: Global Perspectives
Safety & Health in Agricultural & Rural Populations (SHARP), Saskatoon,
Saskatchewan, Canada October 19-22, 2014
Abstract
This presentation explores risk factors associated with children and noise in general and from
exposure to industrial wind energy facilities. Wind power has been proposed by some as an
approach towards the reduction of greenhouse gases. The author searched World Health
Organization publications, PubMed; Google Scholar and considered anecdotal reports
associated with this topic. Search terms included wind farms, wind energy, noise, health
children and noise. Industrial wind turbines emit noise. There is a risk of noise-induced harm
to children when industrial wind turbine facilities are sited in close proximity to family
homes and schools. The World Health Organization (WHO) acknowledges that noise is an
underestimated threat that can cause a number of short- and long-term health problems
Research indicates childrens ear damage, cognitive function and learning are affected by
noise and there could be lifelong effects on academic achievement and health. Excerpts from
The World Health Organizations Training Package for the Health Sector on Children and
Noise identify vulnerable groups of children at risk including the fetus and babies; preterm;
children with dyslexia and hyperactivity. Children with pre-existing medical conditions such
as autism, asthma, migraine, bronchitis, and epilepsy can be vulnerable to the effects of noise
and/or stress and/or sleep disturbance. Research conducted in Ontario, Canada documents
that some individuals living in close proximity to wind energy facilities report physiological
and psychological symptoms, reduced quality of life, degraded living conditions, and adverse
social and economic impacts. Research on children and industrial wind energy; vigilance and
long term surveillance systems related to children and IWTs are lacking. Precautionary
measures are lacking for children in public or private child care centres, schools or other
24
institutions that care for children part- or full-time. Some children may be limited in their
ability to play outdoors. Results are, based on peer reviewed research on effects of noise in
general and anecdotal reports associated with IWTs there is a risk of negative effects for
some.
_____________________________________________________________
Krogh, Carmen ME; Morris, Joan; May, Murray; Papadopoulos, George; and
Horner, Brett
Trading off human health: Wind turbine noise and government policy
Paper presented at the Wind Turbine Noise conference 2013, August 28 to 30, Denver,
Colorado, USA
Abstract
Noise is considered a threat to public health that can seriously harm humans. Understanding the
health impacts of noise has advanced significantly over past decades. Some jurisdictions responded
by implementing policies to reduce the negative health effects of transportation and industrial noise.
These gains in health protection from noise are under threat. In Canada government policies to

72
support wind energy development have been adopted, in part, to reduce dependency on fossil fuels.
However, wind energy facilities can produce unwanted sound and negative health and social
economic effects when sited too close to humans. Peer reviewed literature, case reports, and access to
information documents are used to evaluate government policies in Canada. Together these sources
support the conclusion that human health is being traded off in favour of government policies that
support wind energy development. This trade off conflicts with international charters that
acknowledge the highest attainable standard of health is a fundamental right of every human being.
______________________________________________________________
Krogh, Carmen ME; Jeffery, Roy D; Aramini, Jeff; and Horner, Brett
Wind turbines can harm humans: a case study
Paper presented at Inter-noise 2012, New York City, NY
Abstract
In Canada the Ontario Government has adopted wind energy as a renewable energy source. Our
research in Ontario documents some individuals living in the environs of wind turbines report
experiencing physiological and psychological symptoms, reduced quality of life, degraded living
conditions, and adverse social economic impacts. Some families have abandoned their homes or
negotiated financial agreements with wind energy developers. Wind turbine noise is a reported cause
of these effects; however, some commentators suggest sound from wind turbines does not pose a risk
of any adverse health effect in humans. These competing claims can confuse authorities responsible
for establishing noise guidelines. An Ontario Environmental Review Tribunal considered a wide body
of evidence including expert testimony and found wind turbines can harm humans if placed too close
to residents. Risks must be understood to ensure guidelines protect human health. Evidence including
peer reviewed literature, case reports, freedom of information documents and expert testimony will be
presented which support the conclusion that wind turbines, if placed too close to residents, can harm
human health.
_____________________________________________________________________
Krogh, Carmen ME; Jeffery, Roy D; Aramini, Jeff; and Horner, Brett
Wind turbine noise perception, pathways and effects: a case study
Paper presented at Inter-noise 2012, New York City, NY
Abstract
In Ontario Canada wind turbines are being sited close to humans. Wind turbine noise is perceived to
be more annoying than other equally loud sources of sound. This annoyance can contribute to stress
related health impacts. An Ontario government commissioned report concludes a nontrivial

25

percentage of exposed persons will be impacted. Our research documents some Ontarians living in
the environs of wind turbines report experiencing physiological and psychological symptoms,
reduced quality of life, degraded living conditions, and adverse social economic impacts including a
loss of social justice. In some cases the effects resulted in families abandoning their homes. Others
have negotiated financial agreements with wind energy developers. An Ontario Environmental
Tribunal considered a wide body of evidence including expert witness testimony and found that wind
turbines can harm humans if placed too close to residents. Peer reviewed literature, case reports,
freedom of information documents and expert testimony will be presented which support the
conclusion that noise perception via the indirect pathway can result in serious negative effects.
_____________________________________________________________________
Krogh, Carmen ME; Jeffery, Roy D; Aramini, Jeff; and Horner, Brett
Annoyance can represent a serious degradation of health:
wind turbine noise a case study
Paper presented at Inter-noise 2012, New York City, NY
Abstract
Annoyance is often discounted as a health concern. Wind turbine noise is perceived to be more
annoying than other equally loud sources of sound. The Ontario government commissioned a report
which concludes a non-trivial percentage those exposed to wind turbine sound will be highly annoyed
which can be expected to contribute to stress related health impacts. Our research in Ontario, Canada
documents some individuals living in the environs of wind turbines report experiencing physiological

73
and psychological symptoms, reduced quality of life, degraded living conditions, and adverse social and
economic impacts. Some families have abandoned their homes or negotiated financial agreements with
wind energy developers. An Ontario Environmental Review Tribunal considered a wide body of
evidence including expert testimony and found wind turbines can harm humans if placed too close to
residents. Evidence including peer reviewed literature, case reports, freedom of information documents
and expert testimony are presented which support the conclusion that annoyance can represent a
serious
degradation of health.
_______________________________________________________________________

Lenchine VV and Song J, Special Noise Character in Noise from Wind Farms
INTER.NOISE CONGRESS IN MELBOURNE, AUSTRALIA, 16 -19. November 2014
http://www.acoustics.asn.au/divisions/VIC/internoise2014/wpcontent/
uploads/2014/10/BookOfAbstracts-Draft.pdf
Noise produced by wind farms may exhibit a multitude of different noise characters, ranging
from amplitude modulation, tonality and low frequency noise. The presence of the noise
characters is able to increase the annoyance factor caused by a noise source significantly. A
penalty to the noise levels is applied in accordance with some regulations when a noise
character is detected. This paper discusses a noise character that can be described as
"rumbling" that was detected during a long term monitoring program which was conducted in
an area adjacent to a wind farm. The objective assessment of the data and subjective
assessment of relevant audio records were performed to analyze the effect. The frequency
spectra of the rumbling events indicate connection of the effect with low frequency noise and
one of the low frequency components. The character was detected at low noise levels and
might not be audible to a typical listener, however it is possible the character may cause an
increased annoyance to people who have a higher sensitivity to the lower frequencies.
Environmental conditions were also considered when discussing the occurrence of this noise
26
character. The possible mechanism of the rumbling effect is suggested in the paper. The wind farm
manufacturers may have to consider potential for low frequency impact of wind turbines and
presence of prominent components at the design stage.
_______________________________________________________________________
McBride DI, Shepherd D, Thorne R Investigating the impacts of wind turbine noise on quality of
life in the Australian context: A case study approach. INTER.NOISE CONGRESS IN

MELBOURNE, AUSTRALIA, 16 -19. November 2014

http://www.acoustics.asn.au/divisions/VIC/internoise2014/wpcontent/
uploads/2014/10/BookOfAbstracts-Draft.pdf

ABSTRACT
The WHO considers noise pollution to be of sufficient threat to public health to justify the publication
of guidelines on noise effects and mitigation. 'Community noise' has largely been studied in the context
of transportation and general neighbourhood noise, with exposure to wind turbine noise relatively
understudied for historical, methodological, and political reasons. There also appears to be a general
uncoupling of wind turbine noise from the other sources, which endows upon it an exclusivity that
excuses it from the methods, guidelines, and critique used for other noise sources. This study aimed to
advance understanding of wind turbine noise impacts by adopting a case study approach based on
detailed information from 25 individuals, Australian adults residing rurally and within 1000-3500m of
three or more wind turbines. Participants were selected on the basis of health concerns evidenced
through statutory declarations or submissions to hearings. The 25 respondents completed a face-to-face
survey measuring health-related quality of life (HRQOL) questionnaire as developed by the World
Health Organisation (WHO), the 'WHOQOL-BREF'. The results were compared to normative
population data and showed clinically significant reduction in HRQOL.
______________________________________________________________
Salt, Alec N. and Lichtenhan, Jeffery T.

74
Responses of the Inner Ear to Infrasound
Fourth International Meeting on Wind Turbine Noise
Rome, Italy, 12-14 April 2011
Abstract:
Unweighted sound measurements show that wind turbines generate high levels of infrasound. It has
been wrongly assumed that if subjects cannot hear the infrasound component of the noise then they
cannot be affected by it. On the contrary, the mammalian ear is highly sensitive to infrasound
stimulation at levels below those that are heard. Most aspects of responses to infrasound are far from
well established. Measurements made within the endolymphatic system of the cochlea show
responses that become larger, relative to measurements made in perilymph, as frequency is lowered.
This suggests that endolymphatic responses to infrasound are enhances in some manner. For
highfrequency
sound, acoustic stimuli in the ear are summed. In contrast, the inner ears responses to
infrasound are suppressed by the presence of higher frequency stimuli. The complexity of the ears
response to infrasound leads us to the conclusion that there are many aspects that need to be better
understood before the influence of wind turbine noise on the ear can be dismissed as insignificant.
______________________________________________________________
Salt, Alec N. and Lichtenhan, Jeffery T.
Perception-based protection from low-frequency sounds may not be enough
Invited paper presented at Inter-noise 2012, New York City, NY
Acknowledgements
This work was supported by grant R01 DC001368 from the NIDCD, National Institutes of
Health. We thank Jared Hartsock and Ruth Gill for their assistance with the experiments.

27

Abstract
Hearing and perception in the mammalian ear are mediated by the inner hair cells (IHC).
IHCs are fluid-coupled to mechanical vibrations and have been characterized as velocity sensitive,
making them quite insensitive to low-frequency sounds. But the ear also contains more numerous
outer hair cells (OHC), which are not fluid coupled and are characterized as displacement sensitive.
The OHCs are more sensitive than IHCs to low frequencies and respond to very low-frequency
sounds at levels below those that are perceived. OHC are connected to the brain by type II afferent
fibers to networks that may further attenuate perception of low frequencies. These same pathways are
also involved in alerting and phantom sounds (tinnitus). Because of these anatomic configurations,
low-frequency sounds that are not perceived may cause influence in ways that have not yet been
adequately studied. We present data showing that the ears response to low-frequency sounds is
influenced by the presence of higher-frequency sounds such as those in the speech frequency range,
with substantially larger responses generated when higher-frequency components are absent. We
conclude that the physiological effects of low-frequency sounds are more complex than is widely
appreciated. Based on this knowledge, we have to be concerned that sounds that are not perceived are
clearly transduced by the ear and may still affect people in ways that have yet to be fully understood.
_____________________________________________________________________
Schomer, Paul
Can wind turbine sound that is below the threshold of hearing be heard?
2013 Acoustical Society of America [DOI: 10.1121/1.4801065]
Proceedings of Meetings on Acoustics, Vol. 19, 040063 (2013)
This paper is geared towards wind turbine sound, but it is really a simple variation on the basic
concepts that this author used in the development of loudness-level-weighted sound exposure
(Schomer et al., J. Acoust. Soc. Am, 110(5), Pt. 1, 2390-2397, 2001) and of Rating Noise Curves
(RNC) (Schomer, Noise Cont. Eng. J., 48(3), 85-96, 2000), which are used in the Standard,
ANSI/ASA S12.2 Criteria for evaluating room noise. The fundamental issue is: Can we hear slowly
surging or pulsating sounds for which the LEQ spectrum is below the threshold of hearing, where
"slowly" means that the pulses come at a rate that is no faster than about 4 pulses per second? The
short answer is yes, and the longer answer is that this effect is a function of the spectral content and
becomes more-and-more prominent as the spectral content goes lower-and-lower in the audible

75
frequency range. So surging or pulsing sound that is primarily in the 16 or 31 Hz octave bands will
show the greatest effect. This paper shows the applicability of these results to wind-turbine sound.
_________________________________________________________
Shepherd, Daniel;, McBride, David; Welch, David; Dirks, Kim; Hill, Erin.
Wind turbine noise and health-related quality of life of nearby residents: a cross sectional study
in New Zealand
Presented at the Fourth International Meeting on Wind Turbine Noise, Rome, 2011
http://otago.ourarchive.ac.nz/handle/10523/2260 24/03/2013
Abstract:
Hearing allows humans to detect threats in the environment and to communicate with others.
However, unwanted sound has the capacity to evoke reflexive and emotional responses, and can act a
stressor. The World Health Organisation classifies noise as an environmental pollutant that degrades
sleep, quality of life and general health. Previous research provides evidence of a relationship
between wind turbine noise and both annoyance and sleep disturbance. However, wind turbines are a
relatively new source of community noise, and as such their effects on health have yet to be fully
described. We report a study exploring the effect of wind turbine noise on health and wellbeing in a
sample of New Zealand residents living within two kilometres of a wind turbine installation. Our data
provide evidence that wind turbine noise can degrade aspects of health-related quality of life and

28

amenity. On this evidence, wind turbine installations should be sited with care and consideration with
respect to the communities hosting them.
______________________________________________________________
Swinbanks, M.A.,
Numerical simulation of infrasound perception, with reference to prior reported laboratory
effects.
Presented at Inter-noise 2012, New York City, NY
Abstract
In earlier presentations, the author has argued that conventional assessments of the perception of
infrasound based on mean (rms derived) sound energy levels underestimate the importance of the
associated crest factor of very low frequency sound pressure variations. By simulating the dynamic
response of the ear at levels close to the hearing threshold, it is apparent that infrasound may be
perceptible at lower levels than those based on long time constant rms assessment. In particular, it
will be shown that the existence of a finite threshold of audibility, together with the added presence of
low level higher frequency noise in the first critical band (i.e. below 100Hz), can imply the perception
of infrasound at significantly lower levels than has hitherto been acknowledged. The results of
simulations will be compared to independently reported effects which have been observed in
laboratory testing by other researchers.
Conclusion (excerpt)
The dBG levels for the wind-turbine infrasound inside the house are 10-15dB lower than the Chen
test signal which gave rise to adverse effects after only 1 hour. But since there is an 8dB increase in
sensitivity for 10% of young adults, it is clear that these infrasonic wind turbine levels could be
expected to become a problem after several hours of exposure.
_____________________________________________________________
Thorne B, The Relevance of the Precautionary Principle to wind farm noise planning

INTER.NOISE CONGRESS IN MELBOURNE, AUSTRALIA, 16 -19. November 2014

http://www.acoustics.asn.au/divisions/VIC/internoise2014/wpcontent/
uploads/2014/10/BookOfAbstracts-Draft.pdf

ABSTRACT
Wind farms consist of clusters of industrial wind turbines which, when placed in rural areas, are
associated with intrusive and unwanted sound. Wind turbine noise has characteristics sufficiently
different from other, more extensively studied, noise sources to suggest that standard industrial noise
standards are not appropriate for measurement and assessment purposes. A seven year study is
reported and, although limited in population size, it is clear that there are definite adverse health
effects related to wind farm noise. Time-aggregated noise metrics have limited utility in assessing

76
individual human health and wellbeing, and a cluster of metrics are needed to describe and estimate
potential effects on individuals and communities. Sleep deprivation is a widely reported occurrence
by people in the vicinity of a wind farm. At this time, however, the quantity and quality of research
are insufficient to effectively describe the relationship between wind turbine noise and health, and
until such time that a definitive relationship is obtained, legislation should apply the precautionary
principle and conservative criteria when assessing proposed wind farm developments.

29

______________________________________________________________
Thorne B, Propagation thresholds and measurement of infrasound to establish separation
distances from wind farm turbines to residences INTER.NOISE CONGRESS IN

MELBOURNE, AUSTRALIA, 16 -19. November 2014

http://www.acoustics.asn.au/divisions/VIC/internoise2014/wpcontent/uploads/2014/10/Bo
okOfAbstracts-Draft.pdf
ABSTRACT
Of all the issues surrounding noise emissions from wind farms, the question of the potential for
annoyance and adverse effects from low frequency sound is one of the most topical. Anecdotal
literature is replete with statements concerning the effects of infrasound and low frequency noise. In
this paper we present objective methodologies to measure and assess infrasound and low frequency
noise in the context of wind farm emissions. The methodologies are reviewed with respect to three
wind farms: one each in New Zealand, Victoria (Australia) and South Australia. The South Australian
review incorporates data from a recent South Australian EPA wind farm study. The calculations for
recommended stand-off distances from wind turbines to residences are presented. The distances are
based on the threshold of annoyance and physiological effects threshold anticipated for different
turbines and frequencies.

57. The period of time for public submissions is inadequate to deal with the extend of
application documentation. The Bord must deemed to be most unlikely to allow
members of the Public Costs to cover the engagement of experts to assist in preparing a
submission. The Bord have refused a request for additional time.
58. The Turbine Drawings submitted are not to scale and are not representative of actual
large wind turbines. The proportions have been under represented, and it not possible
to determine the various cross sections of the proposed blades from the drawing
submitted. I refer the Bord to my complaint and the response from your Mr Doherty.

59. The Bord have failed to ensure the Emlagh File was available on line. This application
refers to it extensively as do the Bord in the PA0214 Application and this PA0046
Application. The costs quoted for paper copies of both can only be described as
swinging and beyond ordinary means.
60. Ireland has 25MW of off shore wind power on the Arklow Bank. The Netherlands
Minister of Economic Affairs has awarded DONG Energy the concession to build The
Netherlands offshore wind farms Borssele 1 and 2. DONG Energy won the concessions
with an average bid strike price, excluding transmission costs of 72.70 EUR per MWh
during the first 15 years of the contract. After that, the wind farms will receive the
market price. Onshore Wind power in Ireland is costing 80 per MWh between REFIT

77

and the Balancing Payment. While it is accepted that the Applicant may not have
capabilities in offshore wind other companies do and could provide off shore wind
power.

http://www.dongenergy.com/en/media/newsroom/news/articles/dong-energy-winstender-for-dutch-offshore-wind-farms
Government Policy is moving to support the development of Wind Power offshore.
http://www.dccae.gov.ie/energy/SiteCollectionDocuments/RenewableEnergy/20140204%20DCENR%20%20Offshore%20Renewable%20Energy%20Development%20Plan.pdf
The Government are even implementing an SEA process for Offshore Wind power
http://www.dccae.gov.ie/energy/en-ie/Renewable-Energy/Pages/OREDP-LandingPage.aspx
61. The Application documentation lists noise levels at hundreds of houses but it is not
possible to determine where these houses are located.
62. The nature of the application documentation is that important information is spread
throughout a huge volume of documentation.
63. It is worth mentioning that the latest figures form SEAI indicate that CO2 intensity per
kWh of Electricity Generation in Ireland increased in 2015 over 2014.

78

See page 21
http://www.seai.ie/Publications/Statistics_Publications/Renewable_Energy_in_Ireland/
Renewable-Electricity-in-Ireland-2015.pdf
More wind power is being added to the Electricity generating system and CO2 intensity
per kWh of electricity generated is rising. CO2 intensity per kWh increased from 456 to
467.5 grams per kWh between 2014 and 2015. That is a 2.5% increase. This is efficiency
going backwards and completely contrary to any holistic intent of the EU Energy &
Climate regime.

79

Please acknowledge receipt of my objection.

Yours faithfully on behalf of our group

Signature__________________________________________________________________
______

Name and contact details for correspondence:

John Callaghan, 10 The Cloisters, Oldcastle Road, Kells, Co Meath

Attachments below

80

ETSU-R-97
Why it is Wrong
Dick Bowdler
July 2005

ETSU-R-97

81

Why it is Wrong

INTRODUCTION
1.1 ETSU-R-97 is used throughout the UK to assess wind farm noise in planning applications. It has
been incorporated into PAN45 in Scotland and PPS22 in England. Nevertheless, it is a thoroughly
flawed document and does not deserve the prominence it has been given.
1.2 The conclusions of ETSU-R-97 are so badly argued as to be laughable in parts (the daytime
standard is based on the principle that it does not matter if people cannot get to sleep on their
patio so long as they can get to sleep in their bedrooms). It is the only standard where the
permissible night time level is higher than the permissible day time level.
1.3 ETSU-R-97 bears no resemblance to standards used for other industrial developments. Other
renewable energy developments have to meet much stricter standards. Each time the Noise
Working Group that drew up the document decide that a particular standard is appropriate, they
follow it up by saying (without putting forward any evidence whatsoever) that such a standard
would restrict development of wind farms and so find reasons to relax it further.

ASSESSMENT OF THE IMPACT OF ENVIRONMENTAL NOISE

2.1 It seems common sense that the impact of a new noise on existing residences is related in
some way to the background noise. For example, if the background noise level at present is
45dBA then a level of 35dB from a new industrial source would probably be inaudible. If the
background noise level at present is 20dB then an industrial noise of 35dB will clearly be heard
and would be very likely to produce complaints.
2.2 Indeed it is normal to set a noise limit relative to the pre-existing background noise when a
new industrial noise is to be introduced into a residential area. Typical planning conditions
imposed by rural local authorities (and sometimes urban ones) require that the new noise be no
more than 5dB above the pre-existing background. This is based on the procedure set out in
British Standard 4142.
2.3 In fact BS4142 does not purport to be a method of assessing nuisance or amenity. It was first
published in 1967 and has since been revised twice though the general principles remain the
same. It is simply a method of assessing the likelihood of complaints. Its origin is obscure and it
has been the subject of endless criticism for a whole variety of reasons. But the fact is that it
works. It has been and is still regularly used to assess noise impact and I do not know of one case
where it has been suggested that BS4142 gave an anomalous result. Furthermore, it was
endorsed by DEFRA in September 1998, the department of government concerned with the
environment at that time. They submitted their Noise and Nuisance Policy under Health Effect
Based Noise Assessment Methods to the EU. This said that BS4142:1997 provides a technical
means of assessing whether or not 'complaints are likely'. The result of an assessment carried out
to BS4142 would normally be relevant to the deliberations of any court considering whether or not
a nuisance exists.

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2.4 BS4142 is not normally used to assess wind farms. This is done using the document ETSU-R-97
The Assessment and Rating of Noise from Wind Farms.
2.5 ETSU-R-97 was written by a Noise Working Group (NWG) of developers, noise consultants,
environmental health officers and others set up in 1995 by the Department of Trade and Industry
through ETSU (the Energy Technology Support Unit). The DTIs mission is prosperity for all by
working to create the best environment for business success in the UK. It has no brief for the
protection of the environment or for the protection of the citizen from nuisance or loss of
amenity. ETSU was the UK Government executive agency for energy technologies.
2.6 The status of ETSU-R-97 is perfectly clear. The preface says The aim of the Working Group was
to provide information and advice to developers and planners on the environmental assessment of
noise from wind turbines. While the DTI facilitated the establishment of this Noise Working Group
this report is not a report of Government and should not be thought of in any way as replacing the
advice contained within relevant Government guidance. The report represents the consensus view
of the group of experts listed below who between them have a breadth and depth of experience in
assessing and controlling the environmental impact of noise from wind farms. This consensus view
has been arrived at through negotiation and compromise and in recognition of the value of
achieving a common approach to the assessment of noise from wind turbines.
2.7 The first paragraph of the executive summary says This document describes a framework for
the measurement of wind farm noise and gives indicative noise levels thought to offer a reasonable
degree of protection to wind farm neighbours, without placing unreasonable restrictions on wind
farm development or adding unduly to the costs and administrative burdens on wind farm
developers or local authorities.
2.8 It is thus, by its own admission, not a method of assessing impact. What is more the
compromise reached by the NWG is so lacking in basis, so full of unfounded assertions and so
badly thought out and argued that it comes up with standards for wind farm noise that are quite
unlike any other noise standards. I need to explain in some detail why this is the case so that my
point can be fully understood.

THE NWG ARGUMENT IN ETSU

3.1 I have explained why the assessment method in ETSU-R-97 is not a measure of impact. I need
to describe how the assessment method was developed by the NWG in order to explain how it
relates to normal methods of measuring impact. The NWG starts by pointing out that the
planning advice relating to noise says that the likelihood of complaints can be assessed, where the
Standard is appropriate, using guidance in BS 4142: 1990. In examining whether BS4142 is
appropriate for assessing wind turbine noise the NWG suggests that there are three reasons why
it might not be. These are:
Wind farms are likely to be developed in largely rural areas and not in the
areas to which the standard is principally addressed, namely mixed residential
and industrial areas; the scope of BS 4142 specifically precludes situations
where background noise levels are below 30dB(A);
BS 4142 recommends that noise measurements should not be taken in extreme
weather conditions such as high wind speed greater than 5 metres per second
average ".
3.2 In answer to the first point they say Although the standard is intended for use in mixed
residential and industrial areas as suggested by its title, there are no obvious reasons which

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prevent its application in more rural areas and indeed Members of the Noise Working Group have
used it in such areas. So BS4142 is not rejected for this reason.
3.3 To the second point they say, after some debate, the question that arises is: if one intends to
apply the principles of BS 4142 to the protection of external amenity, and the instrumentation is
available to accurately measure noise levels below 30dB(A), should a margin above background
approach be pursued in low noise environments or can an absolute level be justified in such
circumstances? They leave the question to be dealt with later. I should point out that since ETSUR-97 was published BS4142 has been revised so that low noise levels are only excluded when both
the background is less than 30dB and the turbine noise is less than 35dB.
3.4 Whatever the NWGs answer to the third reason, and it is not very clear what that answer is, it
is obvious that they accept that there is no reason to reject BS4142 at higher wind speeds because
ETSU itself says that background noise should be measured at all wind speeds up to 12m/s.
3.5 In summary, thus far the NWG seem to find no good reason to reject BS4142 except that it
leaves open the possibility of whether to adopt a limiting absolute level to be dealt with later.
3.6

At this point it is necessary for me to explain LA90 and LAeq. Noise levels can be stated in different
ways. For example if a noise is fluctuating we could talk about the minimum or the maximum or
the average. BS4142, in accordance with international practice, uses the measure LAeq to describe
the specific noise that is the noise to be assessed. This is effectively an average. It is actually a
logarithmic average but that is of no real significance here. Again in accordance with common
practice BS4142 uses LA90 to define background noise. This is the level exceeded for 90% of the
time, so in a ten minute period the noise level is more than the LA90 for an aggregate of 9 minutes.
So the LA90 is usually close to the minimum noise level.
3.7 On the question of turbine noise the NWG put forward the suggestion that LA90 should be used
to measure turbine noise. This is because the measure will eliminate other extraneous noise. For
example, if a site is affected by an occasional passing car, the LAeq may be determined by the car
whilst the LA90 may not. I have no objection to the principle of measuring turbine noise by the use
of LA90. This is a method I often use where the difference between the LAeq and the LA90 is known
and constant. However, it would be much better to measure as LA90 and then add back 2dB (the
difference between the two) to get the LAeq value so that the units remain consistent with BS4142
and other normal practice. ETSU-R-97 carries on describing turbine noise as an LA90 which simply
leads to confusion. BS7445 (Also ISO1996) Description and Measurement of Environmental Noise
makes it clear that environmental noise is to be described as LAeq.
3.8 On Page 59 ETSU-R-97 says It is proposed that the background noise levels upon which limits
are based, and the noise limits themselves, are based upon typical rather than extreme values at
any given wind speed. An approach based upon extreme values would be difficult to implement as
the difference in measurements between turbine noise and background would depend upon the
length of time one is prepared to take data. A more sensible approach is to base limits upon typical
or average levels, but to appreciate that both turbine and background noise levels can vary over
several dB for the same nominal conditions. What they are saying is that, having measured
background noise levels over a period of several weeks we should take the background noise level
at each wind speed as the average of all the background noise levels at that wind speed. This is
completely inconsistent with normal practice and suggesting it is sensible is merely an
unfounded assertion. In using BS4142 in the field we are generally required by local authorities to
measure at the quietest part of the period in question. It is not acceptable, where traffic noise
predominates, to take an average of the LA90 values over, for example, a whole night time period.

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The local authority will require the background noise in the middle of the night when it is quietest.
For example
A letter from Renfrew Council in 2004 in connection with a planning
application says that the impact of noise on nearby dwellings should be
assessed by BS4142 and that the background noise level for the most sensitive
period that the source could operate should be used for this assessment.
At the Portree Co-Op development it was agreed that In accordance with
BS4142 the background noise should be measured as LA90 and the noise from
the development as LAeq. Measurements of LA90 over any specific period should
be carried out in wind speeds less than 5m/s and during a representative part of
the period including the quietest part of the period. The measurements should
be made in intervals of between 5 and 15 minutes. The average and standard
deviation of all the measurements should be calculated and the background
noise taken as the average less one standard deviation. So the level required is
more or less the quietest part of a quiet night.
3.9 In the case of background noise dominated by wind it has been my practice to take the
average and the standard deviation of a group of 10 minute measurements and to define the
period LA90 as the average less one standard deviation. Typically this is about 4dB less than the
average. Statistically 15% of the time the background noise is below this level. Unless there is a
large variation between day and night time background noise I will normally use the whole 24
hour data rather than separate day and night.
3.10 Returning to ETSU-R-97 on page 60, continuing discussion on background noise the NWG say,
Noise from the wind farm will be limited to 5dB(A) above background for both day- and night-time.
When comparing the proposed margin with the complaints criteria suggested by BS 4142 it is
important to bear in mind that the LA90 descriptor is also being proposed for the turbine noise.
The Leq levels can be expected to be about 1.52.5dB greater. An addition of 1.5-2.5dB places the
margin at the upper end of the range which can be considered to be of marginal significance ie
around 5dB. What they appear to be saying is that, because turbine noise is measured as LA90, the
margin above background noise that is proposed is actually 7dB in normal BS4142 terms rather
than the 5dB normally adopted by local authorities. There is nothing in BS4142 that suggests that
7dB is at the upper end of the range which can be considered to be of marginal significance. This
phrase is simply an invention of the NWG.
3.11 Further down page 60 it says that On balance it is considered that a margin of 5dB(A) (by
which it means 7dB in BS4142 terms) will offer a reasonable degree of protection to both the
internal and external environment without unduly restricting the development of wind energy which
itself has other environmental benefits. There is no foundation whatsoever for this assertion. No
evidence is brought forward or referred to.
3.12 So the position in the argument so far is this. The NWG has decided, without any foundation,
that the 5dB marginal significance in BS4142 could be 7dB. It has decided, against all normal
practice, that the background noise level for assessment purposes ought to be the average of
background levels in any particular condition rather than the lowest level. In wind controlled
background noise the average is likely to be at least 4dB more than a realistic background level.
So the NWG consider that 11dB over background is appropriate for wind farms as against normal
practice for industrial noise of 5dB over background noise. Of course I have to bear in mind that
ETSU-R-97 does not purport to offer a method of assessment of impact. So the NWG is proposing
that, for wind farms, a level of noise that is likely to give rise to complaints is appropriate because

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of the particular public benefits of wind farms. I cannot agree with this. As I exemplify elsewhere
other projects of public benefit have to meet the stricter standard of 5dB above background.
3.13 Not content with establishing a margin above background noise far greater than normal, the
NWG, at the bottom of page 60, continues Applying the margin above background approach to
some of the very quiet areas in the UK would imply setting noise limits down to say 25-30dB(A)
based upon background levels perhaps as low as 20-25dB(A). This is
true in principle but in practice turbines generate less noise at low wind speeds and, at cut in,
turbine noise might have to be limited in some areas to as little as 25dB. By the time wind speed
was up to 6m/s the background noise level would be at least 25dB probably more like 30dB and
so this would require turbine noise to be restricted to less than 3035dB rather than 25-30dB.
Limits of this level would prove very restrictive on the development of wind energy. This is simply a
broad assertion. No evidence whatsoever has been adduced to demonstrate this.
3.14 Some measure of loss of amenity needs to be applied in low background noise levels and it is
normal practice in rural Scotland (and sometimes in towns) to use BS4142 even in low background
noise levels. For example:
Co-Op Retail Store, Portree in 2002. Noise of plant from the development
should not exceed the background noise level by more than 5dBA or, if the noise
is tonal, should not exceed the background noise at all at any noise sensitive
property. The background noise at Home Farm Road was measured at 28dB on
a calm night and this was agreed as the background noise.
New factory for Vestas at Machrihanish in 2001. At this new factory (ironically
the factory that makes wind turbines) Argyll and Bute Council require that: The
rated noise level from the development shall not exceed the predetermined
ambient noise level (the L90(A)) at the nearest noise sensitive properties at the
former RAF housing, by more than 5dB(A). All measurements are to be taken in
accordance with BS4142: 1997 with the measurement periods being 1 hour for
the period 0800-2200 hours and 5 minutes for the period 2200-0800 hours. The
night time background noise was agreed at 27dB which was the lowest hourly
level reached during a windless night. Earlier measurements when there was
sea noise and the background was 32dB were not accepted by the council.
In 2004, SEPA, at Roslin in Midlothian, asked for a BS4142 assessment for a
landfill gas generator even though the background noise level was only 27dB.
3.15 On page 61 the NWG say During the night one can reasonably expect most people to be
indoors and it will not be necessary to control noise to levels below those required to ensure that
the restorative process of sleep is not disturbed. A night-time absolute lower limit is therefore
appropriate based upon sleep disturbance criteria. What this says is that a turbine noise level
inside peoples houses of just less than the World Health Organisation say is necessary to get back
to sleep if you wake up in the night is satisfactory. It seems to me this must be the very upper
limit of acceptability, not one that is well balanced. Since then, the WHO has revised its guidance
5dB lower. So the ETSU night standard is now higher than WHO say you need to get back to sleep.
3.16 When they come to day time, on Page 62 of ETSU-R-97, it says It is also the opinion of the
Noise Working Group that there is no need to restrict noise levels below a lower absolute limit of
LA90,10min = 33dB(A); if an environment is quiet enough so as not to disturb the process of
falling asleep or sleep itself then it ought to be quiet enough for the peaceful enjoyment of one's
patio or garden. This is a bizarre statement. It seems that the 33dBA is the 35dB sleep restoration
level set out by the World Health Organisation for inside bedrooms at night. They seem to be

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saying that there is no need for noise levels during the day to be any lower than is necessary to
allow you to go to sleep on your patio on a sunny afternoon.
3.17 Having suggested that 33dB would be satisfactory because people could get to sleep on their
patio they now say that This level would however be a damaging constraint on the development
of wind power in the UK as the large separation distances required to achieve such low noise
levels would rule out most potential wind farm sites. There is absolutely no evidence brought
forward to justify this. A margin of 2km would normally easily achieve this even with the noisier
modern turbines. They argue that Wind farms have global environmental benefits which have to
be weighed carefully against the local environmental impact. So do many other things. They
argue that Wind farms do not operate on still days when the more inactive pastimes (eg
sunbathing) are likely to take place. The suggestion seems to be that the protection of peoples
amenity does not include protecting them whilst sunbathing in their gardens on a slightly windy
day or sleeping on the patio.
3.18 Then, on page 63 there is another leap of credibility: There is no evidence for or against the
assertion that wind farm noise with no audible tones is acceptable up to and including LA90,10min
levels of 40dB(A) even when background noise levels are 30dB or less. This is just nonsense.
There most certainly is evidence against this assertion. The 40dB is actually 42dB in BS4142 units.
This is at least 12dB above background noise level of 30dB or less and BS4142 says there are
likely to be complaints at turbine levels of plus 10dB. Furthermore there is no argument that
BS4142 is not applicable. Even BS 4142:1990 (which was current when ETSU-R-97 was written)
might easily be applicable here. If the wind speed is 5m/s, the background noise 30dB and the
turbine noise 42dB(LAeq) then there is no reason not to use BS4142, it does not exclude itself in
these circumstances. This noise level is also 12dB more than (twice as loud as) the WHO considers
necessary for you to be able to get to sleep.
3.19 They summarise this For periods during the day the Noise Working Group has adopted the
approach that external noise limits should lie somewhere between that required to avoid sleep
disturbance even if the occupant is outside of the property and the higher level that would still
prevent sleep disturbance inside the property. In other words the lowest turbine noise level that
they would adopt, during the day, would be high enough to prevent you getting to sleep on your
patio. The highest level they adopt during the day would not quite stop you getting back to sleep
in your bedroom. Presumably the principle is that, if it is too noisy to sleep outside on your patio
you can be assured you will be able to get to sleep indoors.

CONCLUSION
4.1 ETSU-R-97 is so poor technically that its conclusions have to be queried. It is put together
through a series of unfounded assertions and there has been no research drawn on to justify
them.
4.2 Even if one were minded to accept the suggestion that you should use very low background
noise levels and that there ought to be a level below which it would be appropriate to use an
absolute noise level, the levels proposed by the NWG are not acceptable. The night time level is
45dB(LAeq) and the day time level is 37 to 42dB(LAeq). Most wind farm sites are in rural areas
where background noise levels can easily be 20 to 25dBA when turbines are operating and so the
margin above background could be up to 20dB or more.

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